News to know
The issue: Officials at the American Society of Heating, Refrigerating and Air-Conditioning Engineers, Atlanta, are working on a revision to its standard 90.1 to increase building energy efficiency by 30 percent by 2030, including a proposal to reduce the window-to-wall ratio to 30 percent from the current 40 percent maximum, on the prescriptive path. Other proposals will limit the light-to-solar-heat-gain ratio for the prescriptive path in the standard, and provide designers with a set of tables with new product U-value and solar heat gain coefficient requirements.
The impact: The proposed revisions affect glazing, including complete changes to the U-factor and SHGC requirements, a new proposed requirement for visible light transmittance and lowered glazing area. “The proposed U-factors are significantly lower, and will push the use of advanced thermal break technology across the country, as well as low-E, argon and warm-edge spacers,” said Tom Culp, president, Birch Point Consulting LLC, La Crosse, Wis. “Basically, you will have to throw everything you have at the window in order to comply.” The new VT requirement also is controversial, Culp said. “Although its intention of promoting daylighting is good … the initial proposal—of VT/SHGC > 1.5—was proven to be proprietary in operable windows where only one glass type could simultaneously comply with both the VT and SHGC requirements. Note that this is the whole assembly VT/SHGC number, not just the center-of-glass LSG [light-to-solar gain ratio], and the frame has a significant effect on the number.” Some of the criteria, for example the LSG and amount of glazing area, are being proposed without background supporting data, said Helen Sanders, vice president, operations, Sage Electrochromics Inc., Faribault, Minn. “The trend to lower glazing area is troubling for the glazing industry as it will result in lower sales,” she said. “If the window area in the envelope goes from 40 percent to 30 percent in this revision, what will happen in the next revision?”
What you can do: The industry will need to work together to provide data that shows that continuing to reduce the amount of glass in buildings is not the path to reducing energy usage in buildings, and the use of glass with different solar heat gain properties on different elevations can result in greater energy savings. Support the advocacy efforts of the various trade associations that are defending their interests, like the Glass Association of North America, Topeka, Kan.; Aluminum Extruders Council, Wauconda, Ill.; National Glass Association, McLean, Va.; Insulating Glass Manufacturers Association, Ottawa, Ontario; and American Architectural Manufacturers Association, Schaumburg, Ill.
The issue: In April, the U.S. Environmental Protection Agency issued new lead paint regulations, requiring that renovations and repairs—including window replacements—in pre-1978 homes be conducted using lead-safe work procedures. The Lead Renovation, Repair and Painting Rule requires that contractors be trained and certified in lead-safe work practices. The EPA issued an extension for compliance to the new rules in a June memo, and announced it will begin to enforce the rule Oct. 1. In an April 23 release, EPA officials announced plans to apply the lead-safe work practices to renovations on commercial buildings. If passed, the rule for the commercial industry could go into effect in July 2011. Additionally, the EPA has proposed to amend the residential LRRP rule to mandate clearance testing. The rule would require that EPA-certified dust samplers, risk assessors and lead inspectors collect lead-based paint dust samples and prepare clearance testing reports. Contractors would be required to perform lead-based paint clearance tests and share results with the client, and lead-based paint dust clearance levels would need to be achieved before a job is considered complete. At the end of a job, a contractor would have to hire, or have on staff, an EPA-certified inspector, certified dust-sampling technician or certified risk assessor to collect dust samples to send to an EPA-accredited lab to conduct clearance tests.
The impact: Respondents to a recent survey from the Window & Door Dealers Alliance, McLean, Va., reported a significant negative impact from the LRRP rule. As reported in a June 15 Window & Door article, more than 70 percent of survey respondents say they have lost business since the rule went into effect in April. Contractors trying to follow the new rules are losing business to competitors who refuse to abide by it, and some customers don’t want to pay the additional costs or take the additional time required by the LRRP rule, according to survey respondents.
The EPA also estimates that contractors would incur a minimum cost of $250 to complete the proposed lead-clearance testing. Firms not following the LRRP rule could face penalties up to $37,500 per day, per violation.
What you can do: Get involved, get educated and, if your business is affected, get trained and certified in lead-safe work practices. For commercial contractors, support the efforts of the National Glass Association, McLean, Va., which is leading an effort to fight the proposed lead-safe work practices for renovations and repairs in commercial buildings. For residential contractors, support the efforts of the WDDA, which plans to ask the EPA to strike the proposal for the lead-clearance testing requirements, or delay the comment period by 90 days to gather hard and soft cost estimates. Residential contractors can also take the WDDA survey at http://www.surveymonkey.com/s/MHDCQ59 to help the alliance gain more information about how the rules are affecting companies.
Climate change legislation
The issue: In June 2009, the House of Representatives passed The American Clean Energy and Security Act of 2009. The bill, introduced by Rep. Henry Waxman (D.-Calif.) and Rep. Edward Markey (D.-Mass), proposes cutting U.S. carbon emissions to 83 percent of their 2005 levels by 2020, and thereafter impose progressively steeper cuts on the emitters. It also would mandate power companies to draw a fifth of their electricity from renewable sources, such as wind and solar, by 2020.
The impact: Like most other energy-intensive industries, the glass and glazing industry is concerned that the measure would increase the cost of its products and hurt production. Potential GHG cap and trade legislation will impact the glass industry in two main ways: cost and technology, said Michael Turnbull, director of international and environmental management, Guardian Industries, Auburn Hills, Mich., in an interview last year. “There will be two significant direct costs under a cap and trade program: annual purchase of allowances, and increase in demand and cost for natural gas,” he said. In terms of allowances, “as a rule of thumb, a typical float glass-melting furnace emits approximately 100,000 tons of GHGs per year, Turnbull said. “[In 2009], the RGGI [Regional Greenhouse Gas Initiative] auction price for a ton of GHG was approximately $3.25. Therefore, if the federal cap and trade price set point is similar, the average float plant in the U.S. would have an additional annual expense of $325,000 to make glass.”
The European Union Emission Trading System price point is about $25/ton. If the federal cap and trade price point is similar, the average float plant in the U.S. would have an additional annual expense of $2,500,000, Turnbull said. “As the EU-ETS is a more mature and comprehensive cap and trade system, it is anticipated that the U.S. cost structure will reflect it and not the RGGI cost structure.”
What you can do: The bill is currently stalled in the Senate, where its proposal to impose emissions limits on sources like power plants, refineries and factories has met the most resistance. At the Glass Association of North America membership meeting at Glass Week this year, Keith McCoy, vice president, energy and resources policy, National Association of Manufacturers, Washington, D.C.,
said he does not expect cap and trade legislation to become a reality “anytime soon” but warned manufacturers to prepare for regulations by measuring greenhouse gas emissions and looking for ways to voluntarily reduce emissions. “Manufacturers need to find ways to mitigate some of the heartburn that’s going to happen in later years,” he said. “Look at your greenhouse gases and implement systems to reduce what you’re emitting.”