The National Fenestration Rating Council (NFRC) is moving full steam ahead with its proposed nonresidential rating and certification program. It could mean significant changes in the construction and building industries, including substantial surcharges on commercial fenestration products and significant time commitments for testing and certification.
The proposed program would create a component modeling system – a computer program that would accurately calculate the energy efficiency of a commercial fenestration unit based on its components such as framing and glass. Although experts say this calculation is exceptionally accurate, the NFRC has proposed additional physical testing and on-site certification to vary results and certify compliance for every single nonresidential building project. Technical experts have declared extra testing and certification unnecessary, saying they are steps that add no value but add significant cost and time. However, the NFRC has disregarded their input and is moving ahead with the program.
While moving forward, the NFRC has failed to address serious questions that may have a tremendous impact on the construction and building industries.
How much will the program cost?
Some industry members have estimated that the proposed program could cost more than $10,000 per building project. This cost will be borne entirely by the builder or building owner.
How much time will the testing and certification process take?
A computer component modeling system takes a matter of minutes to generate a reliable energy calculation. Physical testing of every unit and on-site certification add considerable time and expense to the process. It could take months to get all units for a project tested and certified, but NFRC has not addressed the issue.
Is the testing industry equipped to handle this?
Are there enough testing agencies equipped to provide the necessary physical testing? Are they prepared for a significant increase in volume? If not, significant construction delays could become commonplace.
Few will argue that increased energy performance is undesirable, and reliable energy efficiency calculations could be incredibly helpful to building owners and the construction industry. However, these calculations can be accomplished in an affordable, efficient manner, without redundant and expensive testing and certification. If the NFRC proceeds with their plan, the building industry will pay for the added time and expense. Furthermore, this will become an enforceable part of the building code – not an option.
I read with interest the March 27 blog entry that paints a very unflattering picture of NFRC’s nonresidential rating and certification program. I would like to address a few of the allegations put forth by the author.
It was alleged that NFRC has “disregarded their [the industry’s] input…” Nothing could be farther from the truth. We understand that there are elements of the commercial world that we are still learning about and to help us learn more we recently issued invitations to the Glass Association of North America (GANA), the American Architectural Manufacturers Association (AAMA), the Insulating Glass Manufacturers Alliance (IGMA), the Window & Door Manufacturers Association (WDMA), and the Aluminum Extruders Council (AEC) to attend portions of our Board meetings where the nonresidential program is discussed. We hope to learn from their experience and knowledge of the industry, and are pleased to report that they all accepted. This is on top of our repeated requests for increased industry participation from the commercial glass industry, architects, and others so that they can become a part of the process. In fact, NFRC tapped Greg Carney, technical director of GANA, to serve as a task group chair working on the program and we greatly appreciate the work he has done and the perspective he brings to the discussion.
I also take issue with the statement, “NFRC has failed to address serious questions that may have a tremendous impact on the construction and building industries.” The author then mentions the cost variable as an example. We certainly understand and share the concerns about cost, but please remember that this is still a program in development. Nothing has been finalized. Cost is an important topic being addressed in this process, which is why it’s so important for the industry to participate. That being said, right now, we honestly do not know what the cost will be. But we are looking at every option to keep the program cost reasonable while preserving the program’s integrity. To speculate further would be premature.
The same goes for the other questions you raised. We’re raising them too. And through NFRC’s process each and every one will be addressed and answered. We’re not playing a game of “ready, fire, aim,” but are allowing the program to develop in the most fair, consensus-driven way we know how.
Jim Benney
Executive Director
National Fenestration Rating Council