In response to yesterday's action by the U.S. Environmental Protection Agency's (EPA) seeking additional comments on proposed draft ENERGY STAR Version 6.0 criteria for skylights, the Window and Door Manufacturers Association (WDMA) is calling on the agency to address additional concerns the industry has about the skylight criteria, the proposed window and door criteria and the overall direction of the ENERGY STAR program.
"Yesterday's action by EPA proposing some changes to the skylight criteria is a good first step toward addressing our concerns about product feasibility, availability and cost effectiveness for consumers, but we are still disappointed EPA has not addressed them fully, nor has it provided an explanation why," said WDMA President Michael O'Brien. "It is also still uncertain how EPA will respond to the same concerns raised by WDMA for proposed window and door specifications currently under consideration by the Agency."
The Window and Door Manufacturers Association (WDMA), which has been actively engaging EPA on the revision of ENERGY STAR criteria for windows, doors and skylights, believes the latest revisions make the qualification criteria for skylights more reasonable for much of the country, but that they still fall short and should be improved further.
In a letter sent yesterday by EPA to ENERGY STAR stakeholders announcing the latest revisions to the skylight criteria, the Agency stated the intent of the revisions is to ensure tubular daylighting devices (TDD's) and more double pane skylights will be able to qualify for the Northern climate zone, and to address concerns over the feasibility and affordability of ENERGY STAR qualified skylight products in other parts of the country as well.
However, while the latest revisions are significant improvements in the skylight U-factor criteria for the ENERGY STAR Northern climate zone and Solar Heat Gain Coefficient (SHGC) in the Northern, North-Central and Southern climate zones, they still fall short of fully responding to industry concerns on the whole for skylights with respect to product feasibility, availability and cost effectiveness.
"WDMA has voiced significant concerns with proposed ENERGY STAR Version 6.0 criteria since it was first proposed by EPA last year. The proposed criteria also underscores broader concerns WDMA has with the direction the program appears to be headed in general," said O'Brien. "It appears EPA is more concerned about market share of ENERGY STAR products rather than recognizing efficient products that are most affordable and cost effective for consumers."
WDMA maintains that the proposed Version 6.0 criteria, which is based largely on a market share approach, is counter to EPA's guiding principles for the ENERGY STAR program and resulting in proposed criteria that is less feasible for manufacturers to meet and less affordable and cost effective for consumers.
WDMA firmly reasserted these concerns in a thirty-three page comment letter sent to EPA earlier this month in response to "Draft 2" of the proposed Version 6.0 window, door and skylight qualification criteria. Those comments as well as those submitted in addition by WDMA members are still under consideration by the Agency.
"We will continue to work with EPA to seek further revisions to the Version 6.0 criteria that fully address our concerns and what we believe are in the best interest of the ENERGY STAR program and consumers," said O'Brien.