View Past International Code Council (ICC) and International Enerrgy Conservation Code (IECC) Proposals

KAW 2006 Mid-Year Report

Building on Success
The KAW campaign has evolved into a multi-faceted program, taking AEC into new areas of involvement. Activities during the first two years of KAW included, but were not limited to:

• Retaining an industry expert in a consulting role
• Aggressively opposing all Department of Energy (DOE)-Energy Star proposed changes detrimental to aluminum interests
• Submitting formal comments to DOE on all proposed changes to Energy Star  
  View current submittals
• Participating in Capitol Blitz meeting with key congressional leaders
• Promoting the concept of a Performance-Based Criteria for Energy Star
• Establishing KAW as the voice of the aluminum fenestration stakeholders.

January 2005: KAW Proactive and Recognizable Force

December 2004: KAW Expands Scope & Reach

August 2003 DOE Final Revision-Energy Star-Windows Criteria, Effective August 29, 2003 (Downloadable PDF)

August 2003 Lawrence Berkeley National Laboratory (LBNL) Report on the feasibility of a Performance-based criteria for Energy Star-Windows (Downloadable PDF)

July 2003 AEC's proposal for a Performance-based Criteria for Energy Star-Windows (Downloadable PDF)

2005 - A Year in Review
KAW Enters New Phase
First Battle Won in KAW Campaign
Keep Aluminum Windows: An Interview with AEC's President

2005 - A Year in Review

As the Keep Aluminum Windows (KAW) campaign concludes its fourth year of advocacy for the aluminum fenestration industry, we can look back at a year fraught with success. The mix of activities in which KAW was involved remained relatively constant, however, the priorities given to the various elements within the mix certainly changed. For the first several years of KAW the focus of the campaign revolved primarily around Energy Star and proposals affecting residential fenestration products. In 2005, while still waging the campaign to allow equivalent performance paths for Energy Star certification, KAW turned its focus to the code arena. A compilation of the year's events within both areas is contained in the 2005-A Year in Review pdf above. The year 2005 also brought Tom Culp, Ph.D., Birch Point Consulting into the role of KAW's representative. Tom is well-known throughout the industry and has brought to the campaign the technical tools to aggressively enter into the codes arena, an area that we feel is of the utmost importance.

Most importantly, 2005 has seen our activities, particularly relative to codes, branch into areas affecting the commercial markets, as well as residential. The cooperative relationships with other industry groups that were developed originally in the context of our Energy Star efforts, and that continue to be nourished, have paid dividends as our efforts expanded to working within the codes areas. In addition, KAW, via volunteers and through Tom Culp, continued to take a lead role on various advisory committees.

Highlights of a very active year are contained in the 2005-A Year in Review pdf above. We hope that you agree that 2005 was a banner year for the KAW program!

KAW Enters New Phase

The Keep Aluminum Windows (KAW) campaign has entered a critical and rapidly changing phase. On February 11, 2003 the Department of Energy (DOE) released its proposed changes in the criteria for windows and skylights seeking the Energy Star certification. Although the DOE has proposed two alternatives (i.e. a two and a three zone remap with designated criteria for each) neither alternative is substantively different from the DOE's original May 2002 proposal.

With the stakes so high, the Council has taken the challenge head on. Formal comments, with several proposed alternatives, were submitted to DOE on March 27, 2003. We are pleased to note that numerous AEC members also submitted comments to DOE.

The Council's comments to the DOE, as well as the DOE's proposed standards change can be viewed by clicking on the links at the top of the page.

Most critical is the "fast track" approach DOE is taking regarding their proposal. The proposal was published February 11, comments were due by March 28; final adoption is planned for the end of April with implementation to begin in August.

In an effort to garner congressional support for a performance-based approach to Energy Star standards rather than the design standard approach that DOE has adopted, the Council assembled a delegation to meet with members of Congress and their staffs on April 2nd. Sixteen AEC delegates, including extruder and supplier members, representatives from window manufacturers and builders, as well as AEC staff participated in no less than 21 meetings with Senate and House members and their staff, as well as key personnel on the Energy Committee. In virtually all cases, the delegation and their "common sense" approach towards a performance-based concept for Energy Star Windows was well received and the delegation left the Hill with strong commitments from the majority of member offices visited. The Council will continue to foster the relationships and utilize the contacts made during this initial congressional effort.

To further capitalize on the expertise that was gathered in Washington, the majority of delegates joined AEC staff and legal counsel in meeting with leadership representatives of the DOE's Energy Star program on April 3rd. AEC further clarified the previously submitted comments and focused on the need for a performance-based standard for Energy Star Windows. It should be noted that of the 36 product areas under Energy Star, 32 have performance-based criteria. Although the meeting was productive it was readily apparent that there is substantial internal pressure to fast track the DOE proposal and thus equally substantial pressure to not entertain substantive changes.

The Council will continue to work with senior DOE officials but at the same time will continue its efforts to bring favorable congressional pressures to bear upon the DOE.

First Battle Won in KAW Campaign

In a letter to the Energy Star Windows Stakeholders, the Department of Energy (DOE) announced their decision to withdraw the proposed new criteria for Energy Star® windows doors, and skylights. As DOE explained, they had received "numerous, insightful comments, including some alternative proposals that warrant serious consideration." The current criteria for Energy Star® windows will remain in effect until the alternative proposals are reviewed.

Citing a "lack of empirical data on the role of solar heat gain in certain regions of the country," DOE feels further analysis is necessary before making a determination on the question. The original January 1, 2003 implementation date for the proposed new criteria has been withdrawn without a new date being assigned.

This is good news for the Council's Keep Aluminum Windows (KAW) Campaign. The work, however, is far from over. Members need to continue to be engaged and offer support in this important campaign that affects all extruders, whether or not they are involved in the residential fenestration market.

DOE plans to continue a review of the comments received thus far and conduct additional analysis on the solar heat gain question, subjecting any new body of analysis and any new proposal to public review and comment.

For more information contact the Executive Office.

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Keep Aluminum Windows: An Interview with AEC's President

The Council is spearheading a new campaign, known as "Keep Aluminum Windows," that was introduced at the 2002 Annual Meeting in March. Rand Baldwin, AEC's President, takes an opportunity to explain the campaign and answer some questions that may be on the minds of Council members.

We've heard a lot about "Keep Aluminum Windows" - what's it all about?

The U.S. Department of Energy, in launching its Energy Star program, is moving toward a de facto "national building code" which will have a profound impact on residential window and door systems. Recognizing that this program will directly affect many AEC members - and indirectly affect all AEC members -- the Council is taking an active role in educating regulators, standard/code bodies, material specifiers, and customers on the role of aluminum extrusions within the building and construction marketplace. Our goal is provide a voice for our members in a process where, so far, aluminum extruders have been under-represented.

How is the campaign going so far?

We are off to a good start. We've gotten the word out to members and have also made the DOE sit up and take notice that we are interested and engaged. The AEC Board of Directors committed $25,000 in funding in 2002, so long as it was matched by at least that much contribution from individual companies. Our fund-raising campaign has already reaped over $30,000 in pledges, more than enough to trigger the AEC matching funds. In addition, I am pleased by the outpouring of support from companies in the industry, evidenced by the large number of companies (22) that have participated in several committee and task force meetings convened on this subject in the past four months.

What is happening with the Energy Star Program?

Energy Star, once thought to be a "done deal," has now undergone several significant changes, partly as a result of industry input such as that provided by AEC and its members. A proposal written last year for DOE would have required nearly all windows in the U.S. to achieve a u-factor rating of 0.40 or less to achieve an Energy Star rating. As of May 31 of this year, we have been able to forestall this hastily drawn proposal and introduced a number of new factors that DOE had not considered. In short, we feel we are making progress in fixing a proposed program that would have been a disaster for aluminum extruders, suppliers, and frankly, for customers as well.

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What can members do?

First, get educated. Those not aware of these issues should take a few minutes to get up to speed. I recommend viewing the latest DOE proposal on their web site, which is located at http://www.energystar.gov/opie/windowspec . Comments to this proposal are due to DOE by June 21, 2002. So, by the time this is published, the date will be upon us. However, keep in mind that the Council is already preparing a response and it is likely there will be additional iterations to respond to after this date.

So, my second suggestion to members is this . get involved. As the voice of the industry, we need "amplification." The more companies involved, the louder the voice. We need pledges for funding; we need committee members; and we need members to respond directly to DOE and other government and standards-making bodies. I would ask anyone interested to please contact me for more information.

What if a company doesn't make residential windows or doors. Why should they care?

One-third of all aluminum extrusions sold in North America go into building construction - both residential and commercial. A national building code that threatens to eliminate aluminum window frames could idle many extrusion presses. This would negatively affect all aluminum extruders, regardless of which market they are in.

What is the commercial market effect?

Even more disturbing is the potential for this "negative momentum" to spill over into the non-residential extrusion market. We are aware of proposals being considered within groups like the American Architectural Manufacturers Association (AAMA) and the National Fenestration Rating Council (NFRC) that would impact standards for office and other multi-story buildings. Again, the point is that our industry needs to be engaged on many levels and with many groups in order to help drive these developments.

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How long will this campaign last?

The Council is fully committed to this effort. We expected an initial effort would be at least two years, and the Board approved that commitment. Frankly, we are in this for as long as it takes and as long as the membership supports this.

What are the chances of success for this campaign?

In a very short time, we have made progress. Based on that, I am optimistic we can make a difference. If we do nothing, failure is a certainty. And, failure is not an option.