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Comments for Performance Based Rating System Workshop

Posted by Webmaster on 17. September 2003 11:07

White Paper (PDF 192 KB), Performance Based Ratings for the ENERGY STAR® Windows Program: A discussion of issues and future possibilities, Aug. 2003
Download Adobe Acrobat.

Posted By: P. Marc LaFrance from U.S. Department Of Energy

September 17, 2003 11:07 AM

It is very important for DOE to receive your comments and position regarding a possible performance based rating system prior to the September 30, 2003 workshop. Please indicate whether you believe DOE should pursue this activity and why. If you want DOE to pursue this activity, please indicate which approach discussed in the LBNL analysis paper that you prefer. You can post any generic comment here regarding the workshop or the LBNL analysis. If you prefer, you can post specific technical or climatic comments under the other headings. You also can initiate a new topic. To get started, you just need to "login" (after you have signed up for the forum) from the home page then click on "view topic." You can then either post a comment, or initiate a new topic. You can read this topic and any responses without logging in, but you can only post your comment after you have logged in. If you have problems getting started, please call me at 202-586-9142. Thank you, Marc LaFrance, Technology Development Manager - Windows R&D

Replied By: William Deuschle from Traco

22 - Sep - 2003 7:24 AM

VP Commercial Operations...

Marc, My comment is based on the fact that from May 28th 2003 until Dec 2003 is a insuffcient time period for any Manufacturer to have ANY products recertified to a Metro Dade Compliance. While (Metro Dade) may be a small portion of the Florida market it is essential in that market. Thus if any new code or energy requirement becomes mandatory it must be given a 18 month lead in period. You can not get any product through the Metro Dade system inside that time frame.

Summary ::: From the May 28th letter from DOE. there MUST be a 18 month lead in period before it becomes mandatory or November 2004.
Comment Number two, TRACO is a supporter of the performance based Standard for the entire US Market. Bill Deuschle

Replied By: Mike Manteghi from Traco

22 - Sep - 2003 10:42 AM

R & I Manager

Marc; My comment is based on implementing a new Energy standard that requires 71 weeks for the design modification and impact testing for southern region because all the single glazed products have to be redesigned for insulated glazing. Currently DOE is allowing six months to implement design standard, other organizations such as NFRC and AAMA allow 1.5 to 2 years to implement any new specification. It is important that the DOE looks at the overall product implementation process while introducing any new standards.

TRACO continues to support the performance energy standard proposed by AEC and LBNL

Replied By: Greg Patzer from Aluminum Extruders Council

23 - Sep - 2003 9:04 AM

AEC Position...

The Aluminum Extruders Council (AEC) applauds the Department of Energy's efforts to explore the merits and feasibility of developing a Performance-based criteria for Energy Star '“ Windows. Furthermore we are encouraged with the results of Lawrence Berkeley National Laboratory's (LBNL) initial analysis. Prior to the release of LBNL's 'white paper', AEC forwarded to both the Department of Energy (DOE) and LBNL, a simplified conceptual model of what we believe to be a workable and equitable Performance-based criteria model. This document, which can be viewed at this website, was envisioned as a starting point for further discussions. AEC has examined and analyzed the material put forth by LBNL. It is our position that while all four options, which have been presented, are viable alternatives, LBNL's 3rd option, that of the development of a regression based equation for each zone, is the preferable approach, which should be pursued.

As an organization representing the interests of the aluminum window industry, we look forward to working with DOE and other stakeholders in developing a new criteria which will promote the greatest energy efficiency as well as be material neutral, equitable and ultimately the most beneficial to the consumer. We are cognizant that the development of any such model/criteria must take into account numerous factors. It is our position that such a model can be developed expeditiously if we do not allow the process to become overly complex with negligible additional benefits.

Replied By: Jim DiBacco from Astro Shapes Inc.

23 - Sep - 2003 3:47 PM

Executive Vice President...

My company supports and encourages the development of a Performance Based Rating (PBR) system for fenestration products to qualify for an Energy Star Rating. The existing prescriptive rating virtually eliminates the use of aluminum as a framing material through out the entire country. A PBR would at least make aluminum an option, particularly with applications that demand the unique charateristics of aluminum, such as superior structural performance and long term durability. Aluminum inherently is the leader in recycling as compared to the other framing materials.

As a member of the AEC we support the proposals that they set forth. We agree with the LBNL proposal option 3 and the fundamental concept of a regression based equation for each climate zone.

Replied By: patrick muessig from azon

24 - Sep - 2003 6:43 AM

Support for Performance Based Ratings...

Azon is in full support of LBNL's option #3: The Performance Based Rating Method. It should be a very logical acceptance by all. If the energy codes are truly designed to save energy, than as long as that fenestration product can meet the given energy savings requirements set forth by the DOE than that product regardless of material should have a viable place within the market. It is refreshing to see that LBNL has explored this avenue and views this as a feasible solution. I would like to add that this approach can be significantly more accurate in saving energy than the current prescriptive method and has the ability to be implemented in a timely fashion.

While we support the performance based rating system we also view it as the first step. Because of the characteristics of this system future issues such as LTEP, Green Coefficients (recyclability & environmental), and Safety and Security can be simply integrated into the equation. Performance Based Rating systems are being looked to as the future for energy codes, Canada and the European Union are currently exploring this route and its benefits to their countries.

Replied By: john oconnell from kinco ltd.

24 - Sep - 2003 7:08 AM

Kinco Ltd. Position...

Kinco Ltd. strongly encourages the implementation of a performance based rating system for fenestration products in order to qualify for Energy Star Ratings. NOTHING is gained in regard to any program designed to reduce energy unless it lasts for the life of the product. For fenestration products, the life cycle is 30-50 years. Aluminum products have proven that they will continue to perform at their original design levels for the life of the building or home in which they have been installed. This can not be said for other fenestration products. Various temperature zones will also play a significant part in evaluating long term performance of products. In addition the color of the product can also have a significant effect the long term as well as the short term performance of the product. Some products have not been sold in the southern part of the United States due to their inability to provide long term performance. I also agree with some of the eariler comments that a reasonable time must be provided to allow currently used products to be tested and evaluated for any new requirements proposed by the DOE.

Replied By: cheryl scharff from western extrusions

24 - Sep - 2003 10:08 AM

Exec. Assistant...

Western Extrusions Corp. would like to thank the Dept. of Energy for it's efforts to explore the merits and feasibility of developing a Performance-based criteria for Energy Star Windows. This will give the aluminum window manufacturers much more opportunity to compete. More competition in any marketplace means the products will be better and prices will be lower for consumers. This is a "win-win" situation. Western Extrusions also supports "LBNL" option #3.
Thank you, Charles McEvoy, Exec. Vice President, Western Extrusions Corp.

Replied By: Jamey Rentfrow from Extruders

24 - Sep - 2003 1:08 PM

Support for Performance Based Ratings...

Extruders, Division of Atrium Companies is in full support of the DOE's efforts to explore the merits & feasibility of developing a Performance Based Rating for Energy Star- windows. Extruders agrees with the LBNL's proposal of option 3, a Regression based approach. We believe that a performance based rating would make aluminum a viable option, especially in applications that require superior structural performance and long term durability. Aluminum products have also proven that they will continue to perform at the tested levels throughout the life of the product. We, therefore, support the Aluminum Extruders Council (AEC) position that such a model can be developed expeditiously.

Replied By: Evelyn Perrett from PPG

24 - Sep - 2003 2:05 PM

National Accounts Manager, Aluminum Extrusion Indu...

PPG supports the development of a Performance Based Rating for fenestration produjcts to quality for an Energy Star Rating. The prescriptive rating eliminates the use of aluminum as a framing material throughout the U.S. A Performance Based Rating gives the market the option of a superior structural performance and the longest life durability of aluminum. Aluminum is king of recycling. The attributes of aluminum is far less waste, energy savings, reduced environmental impact, and the conservation of natural resources - all attributes associated with sustainability. Recycling of aluminum is an appeal to intelligence, resourcefulness, and good business sense.
As a member of AEC we support the proposals that they set forth, we agree with option 3 and the fundamental concept of a regression based equation for each climate zone.

Replied By: Michael Nau from PGT Industries

24 - Sep - 2003 2:37 PM

Product Engineer...

PGT Industries fully supports the proposal to establish a Performance based alternative to the prescriptive requirements of the newly adopted Energy Star program.

After review of the Report and the options offered for discussion by Lawrence Berkeley Laboratories, it is our opinion that 'Option 3' the Zone based Regression equation would best suit our needs. This option is best suited where computer systems are already in place to accommodate the wide variety of product options needed for NFRC temporary labeling.

We do however take exception in placing a maximum 0.80 or any other U-factor in this program. Currently the Florida Energy code (Chapter 13 Sub-chapter 6) has demonstrated that it meets or exceeds the IECC minimum energy requirements and there is no minimum U- factor in the Performance based program. Making the numbers more stringent is not always the way to obtain optimum energy performance.

Replied By: Richard Voreis

24 - Sep - 2003 3:36 PM

DOE Workshop Forum Comments...


I fully support the energy saving goals of Energy Star; however, like the other 32 of 36 Energy Star rated products, I much prefer the performance based approach in lieu the anti-competitive design based approach. The design based approach to be enacted by Energy Star later this year will put aluminum windows out of business in 95% of the United States. As I have pointed out previously, there are other very serious and far reaching ramifications if aluminum windows are no longer available to consumers and builders.

With a performance based standard aluminum, vinyl or any other window frame material can meet or exceed Energy Star's performance standards. For example, in the Central Climate Zone if a vinyl window can do it with a 0.40/0.40 and an aluminum window with a 0.45/0.35 (U-Factor/SHGC) and both save the amount of energy deemed important to Energy Star, then it should not matter how the products produce the desired results.

I have reviewed the White Paper prepared by LBNL. All four options seem to be viable alternatives. In my opinion, the best choice is the 3rd option, which is the development of a regression based equation for each zone.

Thank you for making it possible to express my views on this very important matter.


Richard D. Voreis, CEO
Consulting Collaborative
Dallas, Texas


25 - Sep - 2003 6:22 AM





Replied By: Martin Koppers from Alenco

25 - Sep - 2003 7:09 AM

Engineering Manager...

Alenco supports the development of a performance based rating system that would provide a level playing field for all products regardless of frame material.

We support the implementation of option #3 as proposed by LBL. It is our request that this method be finalized and implemented quickly. The prescriptive requirements that have been recently adopted are biased toward vinyl and wood frame products since they do no allow the tradeoff between U-Factor and SHGC.

If a level playing field cannot be achieved in a very short period of time, the damage to the excluded manufacturer's ability to compete will have been done, and development of the alternative approach will be a mute point.

Replied By: Ken Holbrook from Columbia Extrusion Corp.

25 - Sep - 2003 8:09 AM

National Sales Manager...

Columbia Extrusion Corp. d.b.a. Columbia Commercial Building Products is very grateful that the Dept. of Energy is taking the steps to explore the merit and feasibility to developing a Performance-based criteria for Energy Star Windows. This will give all aluminum window manufacturers much more opportunity to compete on a level playing field as well as giving consumer the ability to buy a product that performs as well as last. Aluminum windows have proven their ability to last over time and I feel that to limit their use in the market would only increase the cost to consumer. Ultimately the more competitors in the market the lower the price will be to the consumer. I would also like to state that Columbia Commercial Building Products supports 'LBNL' option #3.

Thank you,

Ken Holbrook
National Sales Manager
Columbia Commercial Building Products

Replied By: Ray VanNess from Seal Craft Corporation

25 - Sep - 2003 8:49 AM

Performance based system supporter..

Performance-Performance-Performance, after all that is exactly what these products are required to do for property owners and building occupants. I am in favor of the DOE working to establish performance parameters for all regions and believe that option three in LBNL's August 1, 2003 will most accurately define performance for those regions.

Replied By: kory Miller from WINCO

25 - Sep - 2003 9:34 AM

Tested Performance Proves The Standard...

An Energy Star Program based on tested performance of materials will best serve the public. Performance by actual testing, not design or favored material standards, will offer true energy efficiency that proves durability. AAMA's AW (Architectural Window) high use and mis-use testing and Dade County's hurricane and large missile impact tests prove the actual performance of materials. A material neutral performance criterion is the only fair and credible approach for a government standard. The public will not be served, nor will they believe a standard that ignores the testing data that proves superior durability and the energy efficiency of thermally improved aluminum windows, whose aesthetics are maintained long after other materials crack, peel, mildew, rot and corrode.
Hopefully performance based standards can be adopted quickly before additional damage occurs to consumers, the adversely affected industries and the environment.
Thank you for your efforts and for this opportunity to discuss the facts.
Gantt W. Miller, AIA

Replied By: Tom Italiano from Don Young Company

25 - Sep - 2003 12:45 PM

Executive Vice President...

The logic for performance-based window standards is stout, and we suspect it should have been considered vigorously earlier in the labeling process. Regardless, with some trepidation, we support Option 3: Zone based Regression expression, since it represents the most equitable present alternative using existing data and procedures, and it can presumably be executed quickly. To be fair, manufacturers must be afforded adequate opportunity to invest their time and money in the transition mandated to meet new, ever-changing standards and performance levels. We appreciate the efforts now made to encourage input from members of our fenestration family who, for whatever reason, had little or no part in framing the parameters that led to present issues. Meanwhile, we will continue to manufacture both aluminum thermally-broken windows and vinyl windows and must participate in the program to the best of our ability.

Replied By: David Thoman from Thermal Windows Inc.

26 - Sep - 2003 2:34 AM


Thermal Windows supports LBNL option #3, regression based model. As a manufacturer of both vinyl and thermally improved aluminum windows our interest is in providing the consumer with a range of options, including security, longevity and durability. It is important to focus on real energy savings and allow the marketplace to develop solutions through competition innovation and invention. This will require a standard which accurately reflects longterm energy consumption. A standard that sets meaningful goals and lets the market determine how to meet them. The many advances in low emissivity coatings would not have taken place if we were all required to use only one type of glass. Provide a level playing field, promote competition and we all win. Thank you, Marc for the opportunity to participate. Sincerely, David Thoman, VP, Thermal Windows Inc.

Replied By: Thomas Culp from ATOFINA Chemicals, Inc.

26 - Sep - 2003 5:32 AM

Support for perf-based EStar system...

I will be at the meeting on Tuesday, where I hope we can push this initiative forward and resolve any technical issues in a short timeframe. If you review our comments from the past several years, we have long supported a performance based system for all climate regions. This is not an "aluminum" issue -- it is simply the correct thing to do. Having only a prescriptive system has an anticompetitive impact in the marketplace ... one product may have a combination of U and SHGC properties which gives better overall energy performance but does not meet the rigid criteria, yet another product with equivalent or lower energy savings that does meet the prescriptive criteria is promoted to the consumer as "better" via the Energy Star label. This is true for different situations with all types of materials: aluminum, vinyl, metal-clad wood, hard coat, soft coat, etc. A true performance based system is the only way to address this issue. Canada has recently adopted a performance-based system, as has Europe with pilot programs in Britain, Denmark, and Sweden. Australia has long had a performance based system. We like to think of ourselves as leaders, yet it is clear we are falling behind.
I will be happy to provide my input on the technical issues, and I am strongly supportive of the work being done at LBNL. Amongst the options presented, option 3 strikes the correct balance between accuracy and ease of use. This approach is similar to that used in Canada and Europe. With the support of LBNL, it can easily be implemented for all 4 climate regions. I encourage you to address any questions about the technical assumptions quickly and efficiently ... while these are valid questions that must be considered carefully, we should not accept any attempt to bog down the process.

Thanks for all your efforts, and I look forward to Tuesday!

Replied By: David Duly Duly from Pilkington NA

26 - Sep - 2003 12:28 PM

Senior Engineer...

Window manufacturers currently produce energy efficient windows that do not qualify as Energy Star windows in the Northern region. A Performance Based Ratings for the Energy Star Windows Program would allow many of these energy efficient windows currently excluded from the program to obtain the Energy Star label. The overall total heating and cooling energy demands of the house will be equal to or less than the current prescriptive requirement of U-factor = 0.35 and SHGC = any.

The white paper indicates that the Northern region does not include a requirement on SHGC (either maximum or minimum) due to the dominant role of U-factor on energy use. Pilkington NA believes the Northern region does indeed have a requirement for SHGC - the value is 'any'. Windows available today have an approximate range of SHGC values between 0.27 out to say 0.56. The Performance based tradeoff table (see below) is based on the establishment of a '˜baseline for trade-offs' maximum total energy use for windows with U-factor = 0.35 and SHGC = 0.27.

Pilkington NA supports Option 2: Zone based Performance Tradeoff Tables. The proposed table (see below) will incorporate the regression equations within Option 3 to establish the performance based tradeoff table.

Performance based tradeoff table - Northern Zone

U-factor SHGC

0.35 any

0.36 >= 0.30

0.37 >= 0.33

0.38 >= 0.36

0.39 >= 0.39

0.40 >= 0.42

Replied By: Rodney Vickers from Builders FirstSource

26 - Sep - 2003 1:53 PM

General Manager...

This organization represents interests of both the aluminum and vinyl window industries. After review of the alternatives in developing a performance based criteria for Energy Star Windows, we support LBNL's option 3 for the development of a regression based equation for each zone.

Replied By: P. Marc LaFrance from US Department Of Energy

29 - Sep - 2003 6:32 AM



September 23, 2003

TO: Rich Karney, U.S. Department of Energy

RE: Windows Performance Based Rating System Meeting
(Scheduled for September 30, 2003)

Dear Mr. Karney:

In order to assist the Department of Energy in their deliberations at the meeting noted above; the National Fenestration Rating Council offers the following input:

1. NFRC does not currently have an Annual Energy Rating Procedure. Further, it should be noted that NFRC has a policy that until NFRC documents are approved by the Board of Directors for publication, all documents are copyrighted drafts; and are for discussion purposes only; neither to be reproduced, relied upon, or used.
2. The NFRC Board of Directors has directed the membership (Annual Energy Subcommittee) to review the full set of assumptions contained in the RESFEN program. This review has not been completed.
3. If the Department of Energy determines that they wish to move in the direction of an annual energy rating system for the ENERGY STAR Windows Program, NFRC is willing to take the lead in developing an annual energy rating for fenestration products.

If you should have any questions concerning this matter, please do not hesitate to contact me.


James C. Benney
Executive Director

Replied By: Keith Christman from The Vinyl Institute

29 - Sep - 2003 8:47 AM

Vinyl Institute opposes change in criteria...

The Vinyl Institute appreciates this opportunity to comment on the August 1, 2003 Lawrence Berkeley National Laboratory (LBNL) Report: 'Performance Based Ratings for the ENERGY STAR® Windows Program: A discussion of issues and future possibilities' and aluminum window manufacturer proposals for changing the ENERGY STAR® window criteria to allow tradeoffs among U-factors and solar heat gain coefficient (SHGC). The Vinyl Institute is concerned that changing the ENERGY STAR® window criteria in this manner would be confusing to consumers, reduce consumers ability to rely on ENERGY STAR® to save money, and not offer energy savings that might justify changing the current requirements to more confusing criteria.

ENERGY STAR® has been a very successful program that has resulted in dramatic nationwide energy conservation. Consumers have also come to rely on the ENERGY STAR® label to help save them money. The proposal to change the criteria to allow tradeoffs between U-factor and SHGC jeopardizes this ability of consumers to rely on the simple ENERGY STAR® label to save energy and save them money. Although lower U-factors always result in energy savings by reducing the transfer of heat through the window in both winter and summer, a lower SHGC may decrease or increase energy consumption depending on a number of site-specific and seasonal factors. Lower SHGC reduces energy consumption when cooling is needed, but increases energy consumption when heating is needed by reducing passive solar heating.

Proposals to tradeoff lower SHGC for higher U-factors rely on assumptions about typical houses, shading and other factors and, although this modeling is useful for determining nationwide energy impacts, the analysis by LBNL fails to consider impacts on individual consumers. Consumers with good summertime window shading either through trees, shades, or window orientation would have higher average energy bills with a lower SHGC window and higher U-factor. Low SHGC windows will not reduce cooling load in this home but would reduce passive solar heating in the winter. In addition consumers in this home may use more lighting to compensate for the lower light levels caused by the low SHGC windows. Both of these factors would cause a consumer who bought these 'performance based ENERGY STAR®' windows to pay higher energy bills.

Under the current criteria, the ENERGY STAR® symbol is a simple way for consumers to identify products that save them energy and money. Trading off U-factor for SHGC could increase energy consumption for many consumers with good shading of windows in summer. Thus, consumers would no longer be able to rely on the simple ENERGY STAR® label to save them money. Each individual consumer would need to consider whether trading off a higher U-factor for lower SHGC would save money in their specific house given its shading situation and site orientation. It would be unrealistic to expect consumers to make choices between these complicated criteria, nor is there any clear benefit in forcing them to consider these complicated tradeoffs.

The proposed changes to the ENERGY STAR® criteria would not save energy on a nationwide basis. The proposed changes would simply complicate the current system with no offsetting benefits to consumers. Thus, the Vinyl Institute is opposed to changes in the ENERGY STAR® window criteria allowing tradeoffs with higher U-factors for lower SHGC's.

Replied By: James Rafftery from Rafftery Sales Company Inc

18 - Mar - 2004 7:56 AM


I am an independent manufacturer's agent, and my mian product lines are windows and patio doors. I have seen some of the points used on the Draft Paper from LNBL, and feel I that I have to make a statement about this. I believe this is an attempt by the vinyl window industry to circumvent normal trade practices and create a 'monopolistic' sales advantage for the vinyl industry. As written, this draft could basically do away with the entire aluminum window and patio door industry. Granted, there are areas of the country where aluminum is not a viable product, however, there is a large expanse of the Southern Zones (which is also an area of anticipated high growth as the 'baby boomers' retire) where an aluminum product is a very viable product.

Aluminum windows can achieve some rather impressive numbers in U-value, R-Value, SHGC, and visible light transmission, through the use of standard glass products, coatings, and thermal-break extrusions. Although these numbers may not be as high as vinyl (or wood) may be able to achieve, they are more than sufficient to meet the requirements of the Southern Zones. Aluminum also offers the builder a viable product line that are proven to withstand the rigors of the Southern climates; without rotting (as some wood products do); without losing their structural ratings (as some vinyl products do as they degrade); and with long term Durability, Environmental Impact, and Tecycle-ability that is superior to both wood and vinyl. Truth be told, many of the vinyl products products are 'stiffened' with aluminum (or steel) re-inforcement in order to meet the requirements of the High Wind and Debris codes of the Southern regions, resulting in a loss of some of their efficiencies.

I strongly urge the DOE to not follow the road that Title 24 went in California. There was a significant impact on the aluminum window and door industry in California, (and their numbers were not as low as the proposed LBNL Draft), and a viable; economic (aluminum products tend to be lower in cost);proven product was removed from the inventory of products available to the single and multi-family contractors: with a marded financial impact on the end user/consumer.

Replied By: Ivan Paredes from General Aluminum Co.

18 - Mar - 2004 10:32 AM

Dir. of Engineering...

Each time I attended the meetings you have sponsored, you have requested a feed back from the attendees, so I decided to do it.
At this point probably you had heard every argument in the book from both sides. I read many of those arguments, but I did not see any emphasis on one of the points used on the Draft Paper form LBL, which is the "Adverse Market Impact". Many window manufactures do not want to share the market, they want to take Aluminum Windows out of the Market through more stringent codes or the Energy Star Program, with unrealistic numbers that aluminum windows can not meet. I believe each product has good application for determined areas, aluminum works well in the South and South Central Climate Zone because of the warm weather and the high pressures.
There are arguments against the trade offs for the South Central, but if we use the Resfen (with LBL update) Program you can determine accurately the right product for the right area. You know there are many cities in the states of Texas, Arizona, California and Las Vegas, that easily qualify for trade offs.

When Title 24 was established in California, aluminum window and door products were affected the most. Many companies had to close their doors and thousands of workers were laid off. Aluminum companies in the fenestration industry would like to compete with the vinyl and wood product companies fairly, however with the proposed changes it seems to be that the Title 24 situation(with lower numbers) is going to be repeated. If these changes are imposed on us, and you realize that it is not completely justified, it will be too late for the aluminum industry. My concern is that we are eliminating almost every market for the Aluminum Window except the South Climate Zone. I feel that we are singling out the aluminum product industry for the benefit of the vinyl and wood industry.
In summation, if we consider the Long Term Energy Performance, Long term Durability Environmental Impact and Recyclability, the Aluminum products are superior.
Knowing you, I believe that you will take in account all factors before any final consideration.

Replied By: Chris Rix from General Aluminum Co.

18 - Mar - 2004 1:22 PM


I realize that a considerable amount of time and effort has gone into the Energy Star Program and I want to begin by stating our company's position.

General Aluminum has always supported strict adherence to energy and building codes. In fact when Title 24 became a reality in California, we were the first thermally broken aluminum product to be certified. We currently have our entire product line certified for use in Florida and registered with the state in conjunction with the new structural codes.

In keeping with our philosophy we fully support the Energy Star Program but the new 4 zone map has created a dilemma that the DOE must recognize. The map itself should be re- examined. The U-value requirements in all zones with the exception of the south zone will effectively rule out the use of aluminum windows. A more in-depth look at the performance based trade-off method is in itself a band-aid to the real problem of the south-central and north central zones which contain wide ranges of climates. To think that the south central zone would contain Phoenix and Atlanta makes no sense.

Secondly, if the current map remains in place you are forcing builders and homeowners to choose vinyl windows over aluminum windows, effectively constricting the available options. The cost of homes in the entry level category as well as move-up homes would likely increase, thus prohibiting some folks of home ownership.

Additionally, aluminum is a more stable material than vinyl. Aluminum does not expand and contract at the same rate as does vinyl. Exposure to the ultra violet rays of the sun has almost no effect on aluminum, but can cause a durability issue in vinyl. Although we produce vinyl windows, we do not sell them into the desert climates where the ultra violet rays are the most harmful. Has long term product efficiency been seriously considered?
Lastly, aluminum is 100% recyclable. Aluminum is by far the most environmentally friendly building material currently being used.

Thank you for your time. As an aluminum window company in Dallas, TX with over 600 employees, 150 active distributors, and in business for over 50 years we respectively request that you please give further consideration to this important subject.

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