Margaret Webb, the executive director of the Insulating Glass Manufacturers
Alliance (IGMA) has issued a statement on the National Fenestration
Rating Council (NFRC). The statement, reprinted from the spring
2008 IGMA newsletter, is as follows:
A number of industry representatives decided not to respond the
most recent round of ballots on the Component Modeling Approach
(CMA) program, letting NFRC know that our reason for not submitting
ballots was NFRC's lack of responsiveness to the industry.
I, and others in the industry, have been trying to work with
NFRC for some time but have met with a lack of success in attempting
to influence NFRC's CMA program to satisfactorily address the
needs and requirements of the commercial industry. While the NFRC
membership has voted repeatedly on the same issues supporting
proposals from the organizations representing the commercial industry,
it's my opinion that the final results have not reflected the
consensus of NFRC's total membership specifically the commercial
side. Items such as spacer system, development of additional libraries
and sub-assemblies, oversight of the manufacturer ACE and lack
of streamlining the process have all been incorporated into the
program and the software under development against the wishes
of many in the industry. One of the more contentious items is
the development of frame grouping rules which has been returned
to the task group for re-development.
There were three negative ballots submitted on the recent CMA
PCP ballot. At this past meeting, Gary Curtis, chair of the CMA
subcommittee (Ratings) cited this as a success for the program.
However industry member, Rich Biscoe of Architectural Testing
Inc. corrected Gary, noting that many of the members of the industry
including the trade associations have publicly stated that they
do not support the system and have intentionally not submitted
ballots. I agree with opinions Rich expressed at the meeting;
a lack of negative ballots should not be construed as a measure
of success, rather, it is a measure of the lack of support by
the commercial industry for the program and a sad statement on
the NFRC process. It appears that NFRC is poised to finalize its
CMA program by January 2009 even without the support of the industry.
Whether the program will be successful remains to be seen. What
benefit will the program serve if industry ignores it, just as
they have ignored the present site-built program?
Seventeen years ago, NFRC was created to address problems in
reporting thermal performance values most of which were laid at
the doorstep of seemingly "fraudulent" manufacturers.
This underlying tone of unjustified mistrust of manufacturers
continues today. All stakeholders that attend the NFRC meetings
have conflicts of interest; many times these interests are diametrically
opposed. The existence of conflicts is not surprising or even
a "bad" thing. What is surprising is that no one seems
to think it important enough to point out clear conflicts or question
proposals that are of benefit only to the proponent. Politeness
appears to take precedence over naming conflicts when you see
them. It's interesting and discouraging to me to attend an NFRC
meeting as a representative of manufacturers, yet feel marginalized
because we support a cost effective, streamlined program, while
it appears to me that other stakeholder groups which financially
benefit from NFRC programs are heralded as defenders of the "public
good."
It's enough to make one want to stand up and say, "The emperor
has no clothes."
