Submission Number: 00002
Received: 3/1/2012 10:41:45 AM
Commenter: Matthew Tangeman
Organization: Custom Glass Machinery Ltd
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Serious Energy, Inc., FTC File No. 1123001
Attachments: No Attachments
Serious Energy has some serious responsibility to clearly state the case for any energy savings claimed. They were happy to be the beneficiaries of the Obama Administration's publicity which makes their responsibility even greater than those who stayed out of the spotlight.
First of all to the FTC, scientific proof sounds good, but what does that mean? Does that mean quantitative analysis by ASTM or other repeatable methods have been conducted by third parties or internally? Should a manufacturer's disclosure include whether or not the tests were done by independent third parties or internally?
Up to claims are fine, but they need to include a basis for comparison.
A Serious Energy triple IG with low-e and argon will be up to 50% more efficient vs a single pane window with clear glass in a non-thermally broken aluminum frame. The efficiency of the building structure before and after window replacement will not necessarily yield these efficiency improvements. Placing a high R value window into a lower R value structure may not yield the desired results. A blower door pressure test should be done to first figure out the amount of air infiltration that robs a structure of energy every day, and poor results remedied before moving onto window replacement. END
Believe it or not, I am in the glass industry and am saying the above needs to happen, because first and foremost I have a duty as an engineer to state clearly the right path to energy efficiency problem solving.
These types of disclosures should be required of all residential window manufacturers and installers. Too many fly by night amateurs make incredulous claims that can not be substantiated. By the time many homeowners need to file a warranty claim, the amateurs have often become a non-functioning entity that will not respond. Alternatively, professional firms need to state their case for how they would help to improve the energy efficiency of a structure.