GANA guides effort to improve 2010 Building Star Energy Efficiency Rebate Act

The Glass Association of North America (GANA) has released a position paper for the industry calling for proposed improvements for commercial windows and glazing in the Building Star Energy Efficiency…

The Glass Association of North America (GANA) has released a position paper for the industry calling for proposed improvements for commercial windows and glazing in the Building Star Energy Efficiency Rebate Act of 2010. The paper addresses the concerns of the glass and glazing industry regarding the proposed legislation and is supported by the following organizations in the industry: o Glass Association of North America (GANA); o American Architectural Manufacturers Association (AAMA); o Aluminum Extruders Council (AEC); o Insulating Glass Manufacturers Alliance (IGMA); and o National Glass Association (NGA). According to GANA, there are flaws in the draft legislation that need to be corrected in order to properly define which type of commercial fenestration qualifies for rebates. In fact, commercial fenestration and residential windows are significantly different, with diverse structural and durability requirements, which also result in different energy performance criteria, ranging from traditional windows right up to curtainwall glazing in glass office towers. The Tier I and Tier II rebate classifications of the Act each propose a single U-factor and Solar Heat Gain Coefficient (SHGC) for each climate zone. While residential fenestration systems typically require only a single U-factor and SHGC per climate zone, commercial fenestration systems require more than one, based on the product type, due to more varied commercial fenestration applications. Moreover, commercial fenestration is often much larger, and experiences wind and other loads that residential window applications never experience. The industry organizations listed above therefore propose the following changes to the Act“s Tier I and Tier II rebate criteria: 1. The current draft of the Building Star legislation only references windows. Proposed change: Where the term qualified window appears, add the phrase including curtainwall and storefront. Rationale: The building industry interprets the word window standing alone as NOT including curtainwall and storefront, which are simply fixed windows in commercial applications, but which can make up as much as 70% of total glazing area in existing commercial buildings. It is important to ensure these vast glass and glazing applications are included within the Building Star legislation and therefore maximize the impact in terms of both energy efficiency and job creation. 2. The draft legislation refers to a single U-factor for each climate zone, rather than accounting for different product types of commercial fenestration. Moreover, the U-factor values in the Act are not based upon requirements approved by ASHRAE or IECC and are, therefore, not consistent with any industry standard. Proposed change: Refer to appropriate sections of ASHRAE or IECC approved standards. Rationale: More than 80% of commercial construction uses metal framing for fenestration to conform to structural and durability requirements, while the proposed criteria seem to only account for non-metal products. The legislation must therefore account for all the different product types. This is the reason both ASHRAE and IECC include separate U-factor categories for different non-metal and metal product types. The simplest solution is, rather than listing all the criteria for each category, to incorporate the appropriate ASHRAE and IECC approved standards by reference. It is also important to be consistent with recognized industry standards to simplify enforcement. 3. The draft legislation only speaks about complete assembly replacement (glazing and frame), and does not deal with the most common methods to retrofit commercial glazing. Proposed change: Refer to appropriate sections of ASHRAE and IECC approved standards. Tier 1 criteria: o Replacement of complete assemblies (including both frame and glazing) shall comply with Table 502.3 of the 2009 IECC using the appropriate NFRC certified climate zone. The equivalent ASHRAE 90.1-2007 Tables 5.5-1 to 5.5-8 could also be referenced, using the appropriate climate zone and non-residential or residential occupancy type. o Replacement of glazing or addition of a glazing panel (excluding the replacement of the frame) shall include at least one low-emissivity coating, as certified by the manufacturer and verified by the auditor. Tier 2 criteria: o Replacement of complete assemblies (frame and glazing) shall comply with ASHRAE 189.1-2010 Tables A-1 to A-8 using the appropriate climate zone and non-residential or residential occupancy type. Rationale: NFRC certification, appropriate for new products when the entire assembly is replaced, including both glazing and frame, is required in the proposed language. However, replacing the entire framing system for curtainwall and storefront is often prohibitively expensive and/or difficult. The most frequently used method in these retrofit situations by the glass and glazing industry is to either replace the glazing or add an additional glazing panel. At present, however, NFRC cannot provide a certified rating for glazing-only replacements. This would mean that the most common and cost effective methods for retrofitting commercial glazing would not be able to participate in this programme due to the requirement for NFRC certification. Another method, which is not provided for in the present draft legislation, is required to verify these products.