Volume 40,   Issue 6                                June  2005

The NFRC Speaks Out

Continuing the Discussion About a Non-Residential 
Rating and Certification System
by Jim Benney

In the April edition of USGlass, Max Perilstein raised the important issue of fenestration rating and certification for non-residential systems (see page 70 of the April 2005 USGlass). He states in the article that he’s “opening up a major can of worms.” I think he’s right, and I think it’s great. As he correctly observes, NFRC has embarked on a process to develop new procedures for rating and certifying the energy performance of fenestration systems in non-residential applications. 

We recognize that this may mean significant changes in the way glazing contractors, architects, specifiers and others do their jobs and how they make their livings. That’s why we want as much input as we can possibly get from the people who will be most affected by these new procedures. Only with their help can we develop procedures that serve the public, allow the building community to meet code requirements already in place and protect against undue economic hardship. I thank Max for doing his part to raise the issue. 

At the same time, Max included a number of factual errors and misconceptions in his article. In the interest of promoting a fair and informed discussion, I feel it’s necessary to correct them, and I appreciate the opportunity offered by USGlass to respond to his article.

First, a little background: Since its inception in 1989, NFRC has had a close relationship with representatives from both the residential and non-residential glass industry. I myself belonged to NFRC for eight years in my role as technical director of the Primary Glass Manufacturers Council, a tenure that included a number of years as a member of the NFRC board of directors. Now, as NFRC’s executive director, my job is to see that NFRC’s projects and goals continue to follow its stated mission to “develop and administer comparative energy and related rating programs that serve the public and satisfy the needs of its private sector partners by providing fair, accurate and credible user-friendly information on fenestration product performance.”

NFRC Activity Supports the Industry
In addition to developing rating and certification procedures, NFRC also supports a great deal of industry research and development that benefits all stakeholders. While with the Primary Glass Manufacturers Council, I worked closely with NFRC and facilitated the development of optical property standards (NFRC 300) and the NFRC Spectral Data Library. NFRC’s support, and that of the U.S. Department of Energy (DOE) among others, for the development of Lawrence Berkeley National Laboratory’s software programs WINDOWS and OPTICS, and the application and use of those programs in determining glazing performance in NFRC’s technical procedures, greatly increased the efficiency of bringing new glass coatings and glazing configurations to the market. NFRC continues both technical and economic support for these programs. In the same manner, NFRC’s support and application of software tools such as THERM continues to increase extruders’ and designer’s knowledge of how product designs impact thermal performance, assisting in bringing new designs to the marketplace faster. 

The bottom line is that awareness of the energy performance of fenestration products and systems is at the core of our being. In addition to assisting “the public” in making educated choices, NFRC also must assist state and local governments in determining whether fenestration products meet locally-mandated energy performance contained in their codes. Other stakeholders include those agencies that establish voluntary programs that encourage energy efficiency; for example the EPA/DOE Energy Star® Window Program and programs sponsored by energy service providers (utilities).

Theoretically, therefore, the ultimate beneficiary is “the public;” however, it is also true that the fenestration industry representatives utilizing energy-efficient technologies benefit as well.

Correcting Errors and Misperceptions
This brings me to addressing some of the misinformation presented in Max’s article. I feel the following statements need some added perspective (the italicized quotes come directly from Max’s article):

“NFRC wants to bring to the commercial side of the business an energy rating system similar to the one it has for the residential side.” In fact, NFRC initially addressed the “commercial side” 14 years ago when NFRC 100 was published in 1991. At the time, NFRC provided a specific rating size for “glazed wall systems.” We took a big step forward in 1999, when we introduced the concepts of a “responsible party” and label certificates (rather than labeling each and every lite of glass) through the Site-Built Certification and Rating Program. Work on the proposed new component rating method began a few years back because of some of the limitations of the existing site built system. This proposed new system has the potential to provide the industry with a better system for rating fenestration products for thermal performance. How is it better? Two examples:

If approved, the new rating system will allow for energy-performance ratings prior to actually building the product, becoming more useful to the designer, architect and specifier.
If approved, the new rating system will allow for energy ratings for the actual size and configuration of the fenestration system being installed on a building rather than the standardized models and sizes currently required. 

“The people within NFRC who know the IECC and IBC issues will continue to push and push these codes to be enforced and enacted so none of us will have a choice but to deal with it.” NFRC is a 501 c(3) organization, and as such cannot lobby. We are called upon occasionally to testify before code bodies considering the adoption of energy codes that include NFRC references or requirements. We always support these efforts through acceptable outreach and education activities (magazine articles, our newsletter, advertising) because they help us fulfill our mission. It’s very important to point out that energy codes in several states, including California, now require NFRC certification of non-residential fenestration systems in certain applications. The main impetus behind NFRC’s new non-residential rating and certification system is that we recognize that the glazing community needs an effective and efficient means to comply with these existing code requirements.

“Whenever the proposed program has been discussed in magazines or at trade-related meetings the NFRC has said its development is due to a ‘mandate’ from the Department of Energy for a rating system to measure the energy efficiency of the commercial building products. However, when researched, I found no “mandate” on the commercial side; only for residential.” Section 121 of the Energy Policy Act of 1992 directs the Secretary of Energy to “provide financial assistance to support a voluntary national window rating program that will develop energy ratings and labels for windows and window systems.” It further states, “Such rating program shall be developed by the National Fenestration Rating Council according to commonly accepted procedures for the development of national testing procedures and labeling programs.” The law does not distinguish between residential and non-residential fenestration systems. 

“It appears the NFRC is dominated by members from testing labs and consultants from the residential industry.” NFRC has approximately 230 members and the great majority of members (approximately 170) are fenestration manufacturers and suppliers. 

“As a start, it is my opinion that GANA should have a seat on the NFRC board. The make-up of the board (which is completely skewed toward residential and testing labs with only one commercial member) needs to be examined.” We would welcome GANA’s participation in NFRC, including representation on the board through the normal election process. NFRC’s bylaws reserve a single seat for laboratories, and five seats for fenestration manufacturers or suppliers. Of those five seats, one each is reserved for a residential manufacturer, a non-residential manufacturer and a glazing in-fill manufacturer. The other two are “at large” seats that can be filled by any manufacturer or supplier. The by-laws also set aside three “general interest” seats that can be filled by any dues-paying member. The current makeup of the board includes representatives from one simulation lab, two residential manufacturers, one non-residential manufacturer, an association representing the broad manufacturing community and one glazing in-fill manufacturer. (It may be a judgment call, but I don’t see that as “completely skewed” toward residential and testing labs.) Of the three seats available for “commercial glazing” representatives, one each will be open for election over the next three years. I encourage interested parties to join NFRC, become involved, take on a leadership role within a subcommittee or committee, and run for the board. NFRC membership is open to all and we continually seek volunteer leaders. 

I hope Max has started a discussion that will carry on into the future and encourage more non-residential stakeholders to get involved in the process of developing a new rating and certification system for their products. I will acknowledge that our efforts to reach out to this segment of the industry have been a little haphazard at times, and I hope the glazing community will acknowledge that they haven’t been paying close enough attention. In any event, NFRC wants to put the past behind us and move forward together. 

The best way to get involved is to join NFRC, which any interested individual or organization can do by visiting our website, www.nfrc.org, and clicking on the “Become a Member” link. Our meetings are open to the public, and we welcome attendance by non-members in any and all sessions (though non-members cannot vote at the subcommittee or committee level). Feel free to also e-mail me to provide input, ask questions or find out how you can get involved. My contact information is below.

Jim Benney is the executive director of the NFRC.  He can be reached at jbenney@nfrc.org.

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