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AMD Responds to Energy Star Product Specification Framework
Last month the U.S. Environmental Protection Agency (EPA) released preliminary findings from the research and analyses they conducted earlier this year regarding proposed 2013 criteria revisions to the Energy Star program for Window, Doors, and Skylights. The findings are contained in the Energy Star Windows, Doors, Skylights Version 6.0 Product Specification Framework document. The EPA asked stakeholders to review these preliminary findings and provide comments. Comments received will be reviewed and considered prior to the full results of these findings being released as the Draft 1 Criteria and Analysis Report in March 2012.
The product specification framework document sets forth which new program elements previously considered will not be adopted during this revision cycle, which elements are to stay the same, what new additions have been incorporated, and which existing requirements have been revised.
• Elements that will not be proposed during this criteria revision is structural performance and life cycle analysis requirements, among others.
• An element that is to remain the same is the four climate zones currently in place which had been revised in the previous criteria revision.
• Requirements worth noting that will be added are air leakage testing and certification, and online manufacturer installation instructions for consumers and installers.
• Current U-factor and SHGC requirements are to be revised:
o more stringent U-factor requirements for windows, sliding glass doors, and skylights (as low as 0.25 for Northern Climate Zone).
o reductions in U-factor and SHGC ratings across all glazing levels for swinging doors.
The document also poses questions to stakeholders for comment and discussion. AMD recently provided comments to some of these questions specifically related to structural and air leakage testing that could have significant impact for door pre-hangers. In summarizing, AMD stated that although structural testing for Energy Star qualification is not be considered at this time, it should not be considered in the future either because there is no correlation between a product’s ability to withstand high wind loads and its energy savings; a product that cannot withstand high winds loses its overall functioning through the damage incurred and would ultimately need to be replaced. The main concern about requiring air leakage testing and certification is the added costs that will be imposed on pre-hangers, which is approximately $1500-$2000 per door configuration tested. If and when either of these two performance requirements is adopted, AMD requested that EPA consider alternative compliance paths for side-hinged doors.
EPA will consider additional comments regarding the Criteria and Analysis Report in the spring and summer of next year and will hold a stakeholder meeting in Washington, DC in April. New program requirements established for 2013 are tentatively scheduled to be published in September 2012, and the 2013 criteria requirements are scheduled to be implemented in the fall of 2013.
November 3, 2011
EPA Looking for Input from Millwork Industry on 2013 Criteria Revisions to the Energy Star Program for Windows, Doors, and Skylights
December 6, 2010
D&R International, consultants for the Environmental Protection Agency (EPA), will be holding a conference call on December 6, 2010 for AMD members and others in the millwork industry who would like to share their concerns or learn more about the 2013 criteria revisions to the Energy Star Program for Windows, Doors, and Skylights.
AMD is assisting the EPA in its efforts to collect input and is soliciting comments from AMD membership at this time. The EPA wants to hear from all stakeholder groups impacted by the proposed Energy Star criteria revisions. So please be sure to mark your calendar and take advantage of this unique opportunity to voice your comments and concerns.
If you are interested in participating in this call, the dial-in information is listed.
AMD Membership Conference Call December 6, 2010
Time: 1:30 PM EST
Conference Dial-in Number: (605) 475-4900
Participant Access Code: 905855#
2013 Criteria Revisions
The EPA, in consultation with the Department of Energy, is considering a variety of revisions to current Energy Star criteria in order to meet the requirements of the Six Guiding Principles for Criteria Revision and to address comments raised during the last criteria revision (principles are numbered below and proposed revisions under each principle are bulleted):
(1) Significant energy savings can be realized on a national basis
- Lower U-Factors in most or all climate zones
- Adjust SHGC in some climate zones
- Expand education on shading and orientation
(2) Product performance can be maintained or enhanced with increased energy efficiency
- Establish installation procedures to ensure product performance
- Add minimum air leakage requirement
- Require some form of structural testing
(3) Purchasers will recover their investment in increased energy efficiency within a reasonable period of time
- Develop equivalent performance criteria for impact-resistant products
- Consider industry proposals for a daylighting credit for skylights and Tubular Daylighting Devices (TDDs)
(4) Energy-efficiency can be achieved with several technology options, at least one of which is non-proprietary
- Allow leeway in thermal performance for specialty products (high altitude and impact-resistant)
(5) Product energy consumption and performance can be measured and verified with testing
- Create/Add a blind purchasing program through the National Fenestration Rating Council
- Resolve the outstanding conflict between the physical and simulation test results for TDD U-factor ratings
(6) Labeling would effectively differentiate products and be visible for purchasers
- Maintain or enhance product and display unit labeling
- Bring market share more closely in line with the 25 percent program target
Revisions to Consider
Four revisions proposed worth considering in terms of their direct impact to AMD members who are already Energy Star partners or are seeking to become one are:
1. Installation Requirement - Could be simply a matter of ensuring availability of proper manufacturer installation procedures and/or Energy Star consumer education on installation, or it could mean requiring products to be installed by a “qualified” installer.
2. Air Leakage Testing Requirement – This might require certification and labeling. Do you already test for Air Leakage? Consider what the additional cost, rollout time, and level of effort for this would be for products seeking or maintaining Energy Star qualification.
3. Structural Testing Requirement – This might require certification and labeling. Do you have structural testing conducted in general or just for products tested in high wind regions? Consider what the additional cost, rollout time, and level of effort for this would be for products seeking or maintaining Energy Star qualification.
4. Verification Testing - Create/Add a blind purchasing program through the National Fenestration Rating Council (NFRC). Scheduled to be implemented as a pilot project sometime in the later part of 2011 and phased-in in 2012 (for additional information see the September 23, 2010 Connected article- Enhanced Energy Star Testing and Verification Requirements Beginning 2011).
Please feel free to also contact Jessica Ferris, AMD’s Director of Codes and Standards, at jferris@amdweb.com if you require additional information or have additional questions.
Final ENERGY STAR Program Requirements
October 26, 2010
Dear ENERGY STAR® Manufacturing Partner or Other Interested Party:
Additional details regarding implementation are provided in the attached EPA cover letter. In particular, the letter:
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Describes the changes made to these Program Requirements, which will be active January 1, 2011. A summary of key comments EPA received on proposed edits to these documents and EPA’s response to these comments is also attached to this email;
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Provides instructions for manufacturer partners to recommit to the ENERGY STAR program and its third-party certification requirements. Questions and answers regarding the recommitment process are attached to this message;
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Explains how partners will qualify products beginning on January 1, 2011; and
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Invites manufacturer partners and other interested parties to join EPA on a conference call on November 12, 2010 at 1:00 PM Eastern Time to discuss the implementation of third-party certification requirements. To participate in this call, please RSVP by November 8, 2010 to ENERGYSTARVerificationProgram@energystar.gov.
Thank you for your continued support of the ENERGY STAR program.
Proposed Revisions to ENERGY STAR Program Requirements
September 17, 2010
Dear ENERGY STAR® Manufacturing Partner or Other Interested Party:
For the past year, the Environmental Protection Agency (EPA) has been working with a wide range of stakeholders to develop, seek feedback on, and implement enhancements to the testing and verification aspects of the ENERGY STAR program. This effort is reflective of EPA’s ongoing commitment to maintain ENERGY STAR’s strength as a brand that consumers can be confident in.
In recent months, EPA has released final requirements for accreditation bodies (ABs), test laboratories, and certification bodies (CBs) that wish to participate in the ENERGY STAR program. Applications for EPA recognition are now available in all three categories and EPA has begun the review and approval process. A current list of recognized ABs can be found at www.energystar.gov/testingandverification. ABs, test labs, and CBs will be added to this list as additional applications are received and approved. EPA recognizes the important role each of these entities will play in the successful implementation of an enhanced testing and verification program, and is doing everything possible to facilitate broad participation.
EPA remains committed to implementing these enhancements to the ENERGY STAR program by the end of this calendar year. It is our intent that they will be made effective through changes to the ENERGY STAR Partner Commitments. The purpose of this letter is to:
- Share and seek input on changes to the ENERGY STAR Partner Commitments that will define requirements for participation in a third-party certification program and for testing products in recognized laboratories.
- Make minor refinements to the Product Specifications for most ENERGY STAR product categories to make them easier for third parties to -interpret and apply.
- Propose more substantive, technical clarifications to the Product Specifications for a limited set of products, taking advantage of this opportunity to seek stakeholder feedback on both matters at one time.
Proposed Revisions to the ENERGY STAR Partner Commitments
EPA has added requirements specific to third-party certification and the use of recognized labs. For appliances, EPA has added a requirement for annual submission of unit shipment data, to bring these product categories into alignment with all other product categories. Finally, to improve readability, EPA has reformatted the document to group together related topics.
Proposed Refinements to ENERGY STAR Product Specifications
As part of EPA’s commitment to creating a clear and effective product qualification process, a limited set of refinements and formatting changes to the Product Specifications, including both eligibility criteria and test methods, have been proposed for most products. These refinements can be characterized as follows:
- Added “family” definitions for product categories where they were lacking.
- Standardized language regarding specification effective dates and significant digits and rounding.
- Applied a consistent format across product types.
For greater ease of use, EPA has reformatted the ENERGY STAR Product Specifications to more clearly and consistently delineate the test method from the performance requirements. This reformatting does not involve any substantive change to the test methods and should not necessitate any retesting of products or the re-accreditation of any lab previously accredited to a specific ENERGY STAR test method.
In cases where EPA and stakeholders are currently or will imminently be engaged in specification revisions, EPA is incorporating the proposed refinements described above into the specification revision process. Revised draft Product Specifications will be posted to www.energystar.gov/productdevelopment, as developed by EPA. EPA is proposing revisions to the Partner Commitments for these products now to provide partners with additional review time. This approach applies to Set-top Boxes (STB), Furnaces, Compact Fluorescent Light Bulbs, Decorative Light Strings, Integral LED Lamps, Residential Light Fixtures, and Solid State Lighting Luminaires. EPA has proposed revisions to the Partner Commitments only for Windows, Doors and Skylights as well.
In addition, EPA has not proposed refinements to the Product Specifications for Digital to Analog Converter Boxes (DTA), External Power Supplies (EPS), and End Use Products that use an External Power Supply as these products have been proposed or determined for sunsetting (i.e., to suspend specification and labeling) by the close of 2010.
Proposed Substantive Clarifications to ENERGY STAR Product Specifications
In a limited number of cases, EPA has taken this opportunity to address stakeholder questions or concerns and has proposed modest changes to Product Specifications.
Summary of Proposed Noteworthy Product-specific Clarifications
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Product Type
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Clarification
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Computers
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Proposed credit structure for products with proxying capability.
Explanation of proper application of internal power supply power factor and hard drive requirements.
Plan to move Game Console Requirements into a Stand-alone Specification.
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TVs
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Finalized use of CEA test procedure for Download Acquisition Mode.
Proposed approach for Power Overhang.
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Window, Doors, Skylights
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Included clarifying language that Sash Replacement Kits (sash packs) are not eligible for ENERGY STAR.
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Central Air Conditioners and Air-Source Heat Pumps
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Required approval from DOE for the Alternate Rating Method (ARM) tool used for simulated ratings.
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Audio/Video
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Included clarifying language regarding proper interpretation of Auto Power Down (APD) definition.
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ENERGY STAR Criteria Revision for Windows, Doors, Skylights
August 16, 2010
Dear ENERGY STAR ® for Windows, Doors, and Skylights Stakeholder: As part of the next criteria revision, EPA invites stakeholders to discuss their opinions on the issues in the letter dated June 14, 2010. The letter is available on the above website. To schedule a conference call between your organization and D&R staff, contact Joe Hart (jhart@drintl.com ) by Friday, August 20. A detailed discussion guide will be supplied to stakeholders in advance of their scheduled calls.
In addition, EPA has been asked to clarify if windows assembled on site can be labeled as ENERGY STAR qualified. As a reminder, the Program Requirements define a window as "an assembled unit consisting of a frame/sash component holding one or more pieces of glazing functioning to admit light and/or air into an enclosure and designed for a vertical installation in an external wall of a residential building." The term "assembled unit" precludes any window that is assembled on site from being eligible for ENERGY STAR qualification.
Sincerely, June 14, 2010
Dear ENERGY STAR ® for Windows, Doors, and Skylights Stakeholder: Please note that future communications will be sent only to primary contacts of your organization (not secondary contacts). ENERGY STAR partners may use My ENERGY STAR Account (MESA) to ensure their status as a primary contact. If you no longer have your user name and password, you can request them from the login page at www.energystar.gov/mesa .
The next process update will be provided before August 15. Questions about updates may be directed to windows@energystar.gov.
May 17, 2010
ENERGY STAR Draft Laboratory Requirements
December 9, 2010
EPA Launches Website to Increase Transparency of Regulatory Activity
EPA Seeks Small Businesses Input on Formaldehyde
October 19, 2010
WASHINGTON – The U.S. Environmental Protection Agency (EPA) is inviting small businesses to participate in an advocacy review panel focusing on formaldehyde. The agency plans to implement regulations for the new Formaldehyde Standards for Composite Wood Products Act, enacted in July 2010.The proposed regulation will establish limits for composite wood products (hardwood plywood, medium-density fiberboard, and particleboard) so these products meet emission standards.
Formaldehyde is a known eye, nose, and throat irritant, and in 1991, EPA classified formaldehyde as a probable human carcinogen. Formaldehyde-based resins are sometimes used as adhesives in composite wood products.
The Regulatory Flexibility Act requires EPA to establish a federal panel for rules that may have a significant economic impact on a substantial number of small organizations. The panel will include representatives from the Small Business Administration, the Office of Management and Budget, and EPA. The panel will ask a selected group of small entity representatives (SERs) to provide advice and recommendations on behalf of their company, community, or organization to inform the panel on impacts of the proposed rule.
EPA seeks self-nominations directly from the small organizations that may be subject to the rule requirements to facilitate the selection of SERs. Self-nominations may be submitted through the link below and must be received by November 2, 2010.
AMD REQUESTS ATTENTION ON EPA – LEAD PAINT REGULATIONS MEMBERS OF CONGRESS RESPOND
April 7, 2010
In early March, on behalf of the Association of Millwork Distributors, its members and the millwork industry, Dan Warren outlined the concerns with the EPA lead paint regulations and an appeal directly to Representative Stephanie Herseth Sandlin in Washington D.C.
First, although the window and door industry recognizes the need to comply, the majority in the industry will not be incompliance by the required date. Secondly, though the rules were promulgated in 2008, the window and door industry was not informed about the need for supplemental training and certification until much later. Third, the regulation originally included an "opt-out" provision allowing customers to sign a waiver releasing liability to the installing dealer as long as there are no pregnant women or children under the age of six living in the home. The understanding is that the opt-out provision may not be part of the final rule.
The appeal presented was two-fold -
The current tax credit for energy improvements is scheduled to expire on January 1. The delay will allow contractors, remodelers and renovators the time needed to attend training courses (which are currently in high demand or even sold-out) and earn their certifications. Without this added cushion, many quality service providers could have their insurance policies canceled due to carriers' concerns about liability associated with the lead paint rules.
Dan communicates the seriousness and potentially devastating issues the regulation is to companies requesting legislature implore the EPA to extend some much-needed breathing room so that compliance does not push more businesses to close.
On March 26th, 2010, a letter endorsed by several members of Congress, was submitted to the Administrator, Office of Information and Regulatory Affairs addressing the April 22, 2010 deadline and the concerns that the necessary steps have not been taken to certify the appropriate number of industry professionals to meet compliance standards.
Dan states, “I strongly encourage our AMD members, their customers and all those associated with the window and door industry to continue to contact their representatives and express your concerns on the EPA Lead Paint Regulation. The time is now. It’s not too late to get involved.”
To view the letter from Congress addressing the concerns with the EPA Lead Paint Regulation, click here
For more information on the EPA Lead Paint Regulation or how to take action and receive a copy of a draft letter outlining the concerns, contact Rosalie Leone rleone@AMDweb.com or mail@amdweb.com.
March 7, 2010 AMD Millwork Magazine
This month’s article is specifically related to the new EPA’s new lead paint rules (officially named EPA's Renovation, Repair, and Painting (RRP) Program). AMD has been following the development of these new requirements and developed an Advocacy Kit for our members and the industry.
AMD is very concerned about the timing and costs associated with complying with and getting ready for the lead-safe compliance deadline of April 22, 2010. Will there be any chance that the deadline for the lead rule to take effect will be pushed back? According to the EPA, the rule will become effective on April 22, 2010, as planned.
As part of the AMD advocacy, members are strongly encouraged to contact their Congressman and policy makers and voice our industry concerns. Though the rules were implemented in 2008, the industry was not informed about the supplemental training and certification until much later. In addition, the regulation originally included an "opt-out" provision allowing customers to sign a waiver releasing installation liability to the dealer as long as there are no pregnant women or children under the age of six living in the home. It is our understanding now that this “opt-out” provision may not be considered in the final rule.
The AMD position requests that-
Just this week an AMD member asked “What type of compliance” is in the works for these regulations. Who will be doing enforcement? EPA states that their staff will be doing enforcement in states that are not yet authorized. State personnel will be doing enforcement in authorized states. That answer leaves a lot to be desired.
Many installers believe that the EPA has grossly understated the cost of compliance. It is felt that compliance will add much more than $35 per job (EPA's estimate) when training, equipment, materials, much slower man-hours, paperwork, etc., are included. It is unclear as to how the EPA determined $35 per job and in what scenarios does the EPA feel that number applies?
For jobs where lead-based paint is present, EPA has estimated that the costs of containment and cleaning verification will range from $8 to $167 per job, with the exception of exterior jobs where vertical containment would be required. These are incremental costs attributable to the rule.
Information collected by EPA for the purposes of the rulemaking indicates that many contractors already follow some of the work practices required by the rule, such as using disposable plastic sheeting to cover floors and objects in the work area. EPA's cost estimates only include the additional steps that those contractors would have to take as a result of the rule.
In addition, in developing the rule, EPA was particularly concerned with having reasonable record-keeping requirements for renovation firms. As a result, the record-keeping requirements specific to the RRP rule are designed to be completed by a typical renovator in 5 minutes or less. EPA believes that the records pertaining to the RRP rule will make up only a small portion of the records renovation contractors typically keep for each renovation job.
Add our voice to AMD in educating our members of Congress as we urge them to delay the effective date of EPA’s new lead paint rules. (http://www.builderonline.com/business/epa-issues-new-lead-paint-rules.aspx)
AMD’s “EPA Lead Paint Rules Advocacy Kit” includes a draft letter (below) that can be personalized to your representatives (find your local representatives onlinehttp://www.contactingthecongress.org/). This letter includes the AMD official stance on EPA’s new lead paint rules. Specifically, AMD’s stance communicates that our industry urges officials to preserve the “opt out” clause of the original draft and support a deferral of the date of implementation.
AMD continues to work on your behalf; AMD Side Hinge Exterior Door Standard (SHEDS) is only one of numerous important projects. AMD also has Certification services for EnergyStar and now, Fire Rating, and we offer a state of the art technology in AMD’s online Education Program. For more information or to have this draft letter emailed directly to you, contact mail@amdweb.com
Rather than distribute revised Partner Commitments and Product Specifications for all affected product categories to all stakeholders, EPA has made these documents, with proposed changes highlighted, available at www.energystar.gov/testingandverification.
EPA welcomes comments on these documents. Please send your comments to ENERGYSTARVerificationProgram@energystar.gov by October 1, 2010. EPA will consider all comments carefully and distribute final Partner Commitments and Product Specifications by mid-October, 2010. Once the documents are finalized, Partners will be asked to complete a few simple steps to confirm their company’s intent to continue partnership with EPA consistent with the revised Partner Commitments.
EPA appreciates your partnership and looks forward to continuing to work with your organization as we enhance the integrity of the program and ensure that the ENERGY STAR continues to be a mark that consumers seek and trust to deliver savings.
Thank you for your continued support of ENERGY STAR.
Sincerely,
Ann Bailey, Chief
ENERGY STAR Labeling Branch
US Environmental Protection Agency
The U.S. Environmental Protection Agency (EPA) is pleased to announce a new criteria revision website where stakeholders can view all announcements about the process. You can visit the website at: http://www.energystar.gov/index.cfm?c=revisions.residential_windows_spec .
Douglas W. Anderson
ENERGY STAR Program Manager
U.S. Environmental Protection Agency
Energy Star Announces Criteria Revision for Windows, Doors, and Skylights
The U.S. Environmental Protection Agency (EPA) is pleased to announce the beginning of a criteria revision for windows, doors, and skylights. A letter from the EPA details the topics under consideration during this criteria revision.
NFRC Testing A Requirement for Energy Star
Dear ENERGY STAR® Partner or Interested Party:
Please find attached to this email an important Memorandum from the U.S. Environmental Protection Agency (EPA). Also attached is EPA’s Draft Conditions and Criteria for Recognition of Laboratories for the ENERGY STAR Program.
EPA welcomes your feedback on the Draft Laboratory Requirements by May 28, 2010.
Thank you for your continued support of ENERGY STAR.
For more information, visit: www.energystar.gov
EPA
WASHINGTON - The U.S. Environmental Protection Agency (EPA) has launched a new website called Reg Stat that will enhance public understanding of its regulatory process and the number, type, and range of regulatory documents developed each year by the agency. This new resource is part of the EPA’s continuing efforts to enhance the accessibility and transparency of its regulatory activities.
Reg Stat provides information on EPA documents published in the Federal Register between 2005 and 2009. It also provides in-depth information on rulemakings likely to be of most interest to stakeholders -- those rules signed by the EPA administrator that substantively amend the Code of Federal Regulations. Users will be able to determine the number of rules signed by the administrator, how long it took to develop each rule, whether a rule underwent Executive Order 12866 regulatory review by the Office of Management and Budget (OMB), and the length of OMB review. Both summary graphics and searchable data tables are available.
An analysis of the data featured on Reg Stat shows that EPA publishes 1,700 to 1,900 documents in the Federal Register each year. Notices, which provide general information of public interest such as meeting announcements, make up the majority of these documents. Approximately 7 percent, or about 100, of those documents are rules that amend the Code of Federal Regulations and require the administrator’s signature; the average time to publish these rules is 974 days.
Users will be able to download and sort the data based on categories of interest. Information on Reg Stat will be updated annually.
More information on Reg Stat: http://www.epa.gov/regstat
AMD President, Dan Warren and AMD staff addressed specifics of the latest controversial Environmental Protection Agency (EPA) lead paint regulations forcing businesses to comply with the EPA Renovation, Repair and Painting (RRP) Program scheduled to take effect on April 22, 2010.
1) Preserve the opt-out provision. This is a common-sense, cost-reducing carve-out that puts control in consumers'
hands while not compromising health and safety.
2) Defer the regulation's implementation date to January 1, 2011, or later.
EPA Gears Up For New Lead Paint Rules
