Controversial CMA

The bumpy and long road to the nonresidential rating program of NRFC nears its end
By Katy Devlin
October 1, 2007
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The process to create a nonresidential fenestration energy rating program by the National Fenestration Rating Council of Greenbelt, Md., has frequently been compared to making sausages: It’s ugly and tedious, but the end product is worth it. 

Since work on the Component Modeling Approach rating program began in 2002, NFRC members and concerned industry representatives have gathered for about 15 meetings in locations from Alaska to Hawaii to Virginia to push the program forward, occasionally through contentious debates. Working groups have met for hours on end during conference calls to hash out details. And events such as the notorious October 2005 CMA task group meeting, where at least 35 people packed into a conference room in Atlanta for a raucous daylong debate, have made the CMA sausage process even less appetizing.

“We’re moving forward, but this has been one of the most painful procedures I have ever been involved in, in terms of developing something,” says Margaret Webb, executive director of the Insulating Glass Manufacturers Alliance in Ottawa, Ontario. “But when you’ve got all the stakeholders involved, it’s going to slow the process down.”

After five years of sometimes slow and difficult work, the program is nearly finished. And participants—mostly—agree the end product is still worth it, as long as a fair program that works for all segments of the industry goes through.

The history
While work on the CMA began in 2002, its roots go back much further—to the beginnings of NFRC.

The organization formed in 1989, and in 1992, the National Energy Policy Act was released, charging the NFRC with developing a voluntary standard for energy performance of windows and window system. This included residential and nonresidential products.

“The first version of NFRC 100 listed a commercial product as one of the products to be rated. That standard wasn’t just for residential product; it was intended for all products. … This was in 1992,” says Jim Benney, NFRC executive director. The commercial product term used in that early document that remains today was glazed wall systems.

While NFRC’s residential fenestration rating program took off, the commercial side lagged behind, with almost no participation from players in the nonresidential market.

“We had people [on the commercial side] getting labels, but they were all in Seattle [where certification was required]. No one else adopted the program, while the residential program just grew and grew,” Benney says.

The aspects of the rating program that worked well for the residential market could not work in commercial projects, Benney says. While a residential window manufacturer produces everything at the plant and can label and test it there, nonresidential systems require products from several manufacturers for the spacer, glass and frame.

To increase involvement in the non-residential market, NFRC began developing the Site-Built program in 1995 that would take into account the challenges of using products from several manufacturers in one window system. In 1999, NFRC published the program, but it received almost no market acceptance, Benney says.

“The program brought more commercial attention to NFRC, but we had manufactures coming in saying Site-Built didn’t work,” Benney says. “The biggest problem was responsibility.”

In the residential market, the window manufacturer is responsible for the rating on the window. Even though the Site-Built program took numerous players into account and required a project certificate rather than individual product labels, it didn’t dictate which player would be responsible for coming up with an overall energy rating.

“An architect would tell the general contractor to get the certification; the general contractor would tell the suppliers; and they would pass it to the glazing contractor. And the glazing contractor didn’t want to do it,” Benney says. “Unless the certification was required, no one would use it. And even when they did, the code officials often didn’t know how to enforce it.”

Even if responsibility was established, the process of getting a rating for each product and then combining to find a rating for the system proved tedious and inefficient—something unacceptable in the market, Benney says.

So, just three years after the Site-Built program hit the market, NFRC went back to the drawing board to come up with another fenestration energy rating program for the non-residential market. CMA was formed.
Jim Benney, Margaret Webb, Marcia Falke, Tom Culp
The program
Benney says the idea for the CMA, which analyzes the performance of buildings, building envelopes and architectural components, came from Charlie Curcija, president of Carli Inc., Amherst, Mass. “He came up with the idea of rating components separately, rather than as a whole system,” Benney says. 

Frame, spacer and glass manufacturers would pay to have their products rated and added to separate libraries. The individual ratings would be pulled together to calculate a total system rating. Curcija performed early tests to ensure the algorithms were possible and presented a technical paper with his findings to the NFRC.

“It appeared to be industry friendly,” Benney says. “The aluminum guys who didn’t want to take responsibility didn’t have to. All they have to do is find out how their frames perform—find out the U-value for their framing system.”

The CMA serves the glass manufacturers the easiest, as NFRC already operates a spectral data library for glass with its NFRC 300 standard. The system is understood, accepted and used by glass manufacturers.
NFRC has developed the program to bring in spacer systems for the spacer library and is nearing completion on the frame side.

In theory, the program will provide manufacturers a seamless way to determine performance ratings for storefront, curtain wall, window wall or skylight systems of any size or shape.

Participants have said it’s hard to make decisions about the usability of a software program before it’s completed. To give users something they can “touch and feel” before the program launches, the NFRC plans to release a lite version of the CMA software in the form of a bidding tool, Benney says. The software will have the rating program without the certification.

The bidding tool will allow the suppliers to give feedback about the functionality of the software before the CMA is finalized, says Marcia Falke, president of Keystone Certifications Inc. in Etters, Pa., and NFRC board chair. “We’re trying to get something out that people can use, and at least we can get feedback on how it’s being used,” she says. “There are still a lot of issues that need to be worked out, and trying to get some of the users involved early on will be good for the NFRC and the industry.”

Companies can use the tool in bidding to architects or contractors to show how their product performs alone and as a complete system.

Benney says a bidding tool version of the software could be complete as early as this month.

The issues
Since work on the program began, the CMA has received more attention for the controversies and debates that surround it than for its potential role in the industry. At this year’s GlassBuild America in Atlanta, Benney and Webb faced off to debate some of these contentious issues.

Arguments over cost, the scope of third party testing and industry involvement—to name a few—have arisen during almost every CMA discussion. Commercial manufacturers argue the program is trying to fit a standardized residential rating program into a complicated commercial market. Laboratory and testing representatives hold firm on maintaining ample independent testing to keep the program valid and meaningful in the market.

Falke says the NFRC board has heard the commercial industry’s concerns and made notable strides to adapt the program. “We’ve been working on this project for five years trying to make it fit the commercial industry,” she says. “We’ve revised the technology, revised the PCP, reduced costs by a significant amount, reduced testing and simulation, increased the grouping rules, and now we’re talking about reducing oversight. We’ve come a long way from the system we had before and spent a lot of time and effort listening to come up with a system that will work with everyone.”

Despite the compromises of the last five years, several major issues remain:

Cost
The NFRC board released a preliminary fee schedule in June that puts burdensome costs onto manufacturers, says Tom Culp, president of Birch Point Consulting LLC in La Crosse, Wis. “I don’t believe with the proposed fee structure … that the program would be widely accepted unless outside funding is obtained to cover the program development costs and reduce fees.”

The proposed fees hit the frame manufacturers the hardest, Culp says, followed by the primary glass manufacturers. “The spacer manufacturers and glazing contractors don’t get off easy, but the fees for them are lower,” he says. “The spacer is a fairly small component of the system. …. And the board didn’t want to put too much pressure on the glazing contractors. But they have to pay for the program somehow, so they put the bulk of the cost on the glass and frame guys.”

Falke emphasizes that the fees are preliminary and could vary greatly depending on outside funding from sources such as the U.S. Department of Energy or the utility companies. Actual costs could also change based on industry participation—the greater the participation, the lower the costs.

“If we assume we get 5 percent participation, the cost will be X amount of dollars. If we have 50 percent participation, costs will be one-tenth of that,” Falke says. “People complain about the costs, but the fastest way to get them down is to get people into the program.”

Bureaucracy
Efficiency is as important to manufacturers as cost, Culp says, and many manufacturers have argued the program as it stands is too bureaucratic with too many levels of testing. “Time is often more valuable than money. … [Manufacturers] need to be able to come back with a bid or certification in very little time,” he says. “This could be a good program, as long as it’s streamlined.”

One major compromise would allow manufacturers to serve as an approved calculation entity, reducing costs and an additional level of testing, albeit with a requirement of 100 percent review from an inspection agency.

Although the NFRC membership voted overwhelmingly at the spring meeting in Austin, Texas, to allow manufacturer ACEs without total IA review, the board reversed the decision.

Culp presented a compromise proposal during the July meeting in Denver. Under the proposal, both independent ACEs and manufacturer ACEs will be subject to 100 percent review from an IA that will rate the quality of each product submission on an A to D scale. If independent ACEs submit five or six reviews with high ratings, they will move to a statistical auditing program where only 10 percent of submissions require approval. A manufacturer ACE would submit 15 products under 100 percent review and then move to the statistical auditing program. The new proposal is subject to board approval.

Industry awareness
Another major point of contention is the widespread ignorance of industry players that the program exists, let alone of the effect it might have on the industry.

In a July 24 e-glass poll, almost 40 percent of industry respondents reported they had never heard of the CMA program. Another 30 percent said they had heard of the program but didn’t know the details. Only 14 percent said they were in involved in the process, with the remaining 16 percent saying they keep up with CMA news but aren’t involved. That unawareness extends beyond the glass industry to the top portion of the building industry. Architects, building owners and specifiers are not involved and uninformed. “There’s a whole segment of the commercial industry that’s going to be impacted that isn’t involved,” Webb says.

Falke agrees NFRC has not had enough communication with industry players but says it is a top priority for the board. “We’re working on a marketing plan and know we need to do a better job. We need to get the word out, and we probably should have been doing it earlier,” she says. Possible outreach efforts the board is considering include attending meetings and trade shows, holding demonstrations and focus groups, and taking directly with AIA members and code officials, Falke says.

Market segments
Unlike much of the residential market, not all commercial jobs are created equal. While a large segment requires stock systems, a growing and increasingly visible portion of the market is using high-performance systems, many custom, Webb says.

While these high-performing systems would achieve high energy ratings, the CMA program remains cost prohibitive. A project with numerous glazing systems, or one custom system, would require manufacturers to pay to put their system in for that single use, she says.

“Of all the commercial fenestration products out there, the ones using energy efficient products are the ones for large, custom jobs,” Webb says. “Conforming to NFRC program means they will be unfairly penalized.”

Culp agrees, using Leadership in Energy and Environmental Design from the U.S. Green Building Council as an example. “Look at how green building is taking off with programs like LEED,” he says. “LEED buildings have great products and manage to do it without NFRC. … We’ve been promoting low-E, thermally broken frames and warm-edge spacers for a long time.”

The segment of the market that will suit the CMA best is the segment that needs it most, Culp says. “There is a need for [the program] in low-rise and storefront where you’re seeing a lot of clear glass with non-thermally broken frames,” he says.

This segment lends itself best to the CMA, because standard systems are generally specified, so manufacturers wouldn’t have to recertify their products for every storefront. But cost still remains an issue, because “that market is even tighter in terms of cost and profit margins,” Culp says. “It’s very competitive, and we need to do [the program] in a way that won’t be a burden on small manufacturers and glazing contractors.”

The end?
Although many issues remain unresolved, the CMA sausage is about done and ready to be served, whether the industry is ready or not.

NFRC plans to launch the program in time to be included in the 2008 California energy standards, Falke says. The deadline for documents to be published for inclusion is May 2008—or two NFRC meetings away.

The major elements of the program that still need to be solidified before publishing include validation testing procedures, frame grouping rules and the labeling. Falke is confident everything can be completed by the deadline.

Webb agrees. “It’ll get done,” she assures. “Worst case scenario, the NFRC board will just push it forward.”

Even if the program fees remain the same and the process time consuming, Culp says there will be early adopters, particularly in the areas that require NFRC certification such as California and Seattle.
But even then, manufacturers will certify the bare minimum of products, he predicts. “I don’t think it will be completely ignored, but it certainly won’t take off without being more affordable,” he says.

For industry representatives looking to get involved before the program goes through, two more chances occur before the May 2008 deadline. NFRC’s fall membership meeting will be Nov. 5-8 in Tempe, Ariz. The spring 2008 meeting will be March 3-6 in Nashville.

Visit www.nfrc.org for more information, and stay tuned to e-glass weekly and www.glassmagazine.com for the latest news. Click here to view a flowchart of the compete CMA process.

 

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