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USGNN Original StoryIndustry Groups - AEC, AAMA, GANA and IGMA - Continue to Stand Up for Commercial Glazing Regarding CMA

For more than three years, a number of trade organizations and associations, each with strong ties to the commercial glass industry, have devoted countless hours toward the development of the National Fenestration Rating Council's (NFRC) Component Modeling Approach (CMA), a program that will certify and label commercial glazing products. Despite the fact that numerous individuals within the commercial glazing industry have spoken out against the development of CMA, seeing it as unnecessary, industry representatives such as the Aluminum Extruders Council (AEC), the American Architectural Manufacturers Association (AAMA), the Glass Association of North America (GANA) and the Insulating Glass Manufacturers Alliance (IGMA) have involved themselves in the development of the CMA in order to ensure that the unique needs of the commercial market are considered and accounted for.

GANA's involvement dates back to 1999. Greg Carney, GANA technical director, arranged and accompanied NFRC executive director Jim Benney, then NFRC's director of education, and Christian Kohler, a Lawrence Berkeley National Laboratory scientist, on visits with curtainwall consultants and an architectural firm regarding NFRC's development of its site-built certification program. According to Carney, both companies questioned the need for the certification program in the commercial construction market.

Carney says by late 2004, GANA members were so concerned about NFRC's new activities in the development of a nonresidential product certification program to replace the site-built program, that they asked the association to get involved in the efforts.

Since those early meetings, GANA has taken an active stance in the CMA's development. GANA representatives have attended all NFRC meetings since 2005 and, along with AAMA, AEC and IGMA, participated in one-day communication meetings with members of the NFRC board of directors in the summer of 2006 and 2007.

"AEC, AAMA, GANA and IGMA representatives have played extremely active roles through participation in multiple task group work meetings and conference calls in the ongoing program development," says Carney. "Through industry organization involvement, the development of the CMA and product databases, and the use of a software tool have brought progress in an effort to help NFRC develop a program for which the program benefit can exceed the cost."

Margaret Webb, executive director of IGMA has also been involved with many of these efforts since very early stages.
"IGMA has been participating in NFRC since 1997. However it wasn't until August 2004 that one of our members raised concerns about the direction of the CMA and the effect it would have on both insulating glass (IG) manufacturers and the commercial industry," says Webb. "In September 2004, IGMA commissioned a study to determine which aspects of the program might have a negative impact on the IG industry. At that point, it was decided that I would represent IGMA at future NFRC meetings."

AEC also has a long history of involvement through some of its member companies. Tom Culp with Birch Point Consulting, representing AEC, has been an active participant the past three to four years.

"Our members have been actively involved since the beginning, first with the technical procedures and then with the proposed certification and labeling procedures. Initially, the CMA methodology was viewed as a potentially valuable technical tool for calculating energy performance of commercial products in a manner much faster and simpler than the current NFRC site-built rating program. That is still our hope, but, lately, we have been very concerned about excessive bureaucracy and cost in the proposed certification program," says Culp. "We have made progress, but there are still significant concerns about the amount of validation testing, unnecessary review and excessive cost and time for certification. We've been actively working to simplify the program by proposing compromises which streamline the process, such as new frame grouping rules to reduce the amount of testing and statistical auditing to reduce the amount of unnecessary review, but structured in a way to still protect NFRC's interests. None of these issues have been completely resolved, and we've had a mixed record so far."

AAMA, which is also an NFRC independent administrator (IA), has also been involved since early on. In fact, an AAMA staff member co-chaired this task group for approximately eighteen months.

"The proper implementation of a well-thought-out CMA program is important to AAMA's commercial and architectural members, and AAMA members and staff are striving to ensure that the final program requirements are fair and do not constitute an unnecessary burden to our members," says John Lewis, AAMA technical director. "It has been a frustrating process at times, as some industry input has been ignored or arbitrarily not deemed in the public interest."

Industry Focus

These groups say they have become involved in this program development because they want to ensure their member companies and the commercial industry are represented.

"As currently proposed, the certification program will hit the frame manufacturers the hardest, because of the validation testing and the frame library fees," says Culp. "We hope it will also provide value in rating and promoting advanced products, but it is not yet clear whether the benefit outweighs the cost. We need to be actively engaged to try to make the program acceptable in the marketplace, so that is beneficial to industry, NFRC and the public."

"The original concept for the CMA program involved the development of an IG unit database," Webb says." While this might not be onerous for residential manufacturers who typically fabricate similar IG unit constructions, it could have posed a huge burden for the custom commercial fabricator who offer ten's of thousands of different glass options and potentially hundred's of different spacer systems. The combinations and permutations for this segment of the commercial market would be incredible and there would be no way to develop a cost and time effective program to address this part of the industry.

What's Next?

As development of CMA continues, these groups say they, too, will continue their efforts for the commercial market, as well.

"GANA recognizes our industry's long-standing efforts to develop responsible energy efficient technologies, and as its representative trade association, is the recognized leader in technical study, collaboration and teaching," says Stan Smith, executive director of GANA. "We do this in conjunction with our membership, a core group of other associations which, along with GANA, have been members of NFRC for many years. Additionally we collaborate with other organizations and agencies, promoting an energy-sensitive attitude within the industry and other related parties. GANA's approach has been more pragmatic, friendly to architects, contractors and building owners, and is a sound resource for those interested in solving energy solutions in the glazing and related industries. We maintain a belief that to be widely implemented any program related to energy efficiency should be technologically sound, easy to apply, time-sensitive and cost-effective."

Carney notes that GANA will continue its involvement with NFRC in the future, despite the time-consuming and expensive process of developing CMA.

"The organizations that have committed so much time and money have done so on in response to the needs of our members. I can't imagine where this program would be if we weren't making the effort to actively participate and to voice the concerns of our members."

Webb says IGMA, also working in conjunction with the other associations, will continue to attend meetings, speak out on issues that affect the industry and continue to participate in task groups. However, at this late stage in the program development, she sees CMA as a "done deal."

"Issues raised by the four trade associations have been answered in a non-responsive manner. Technically, NFRC has responded to our concerns but their answers have not provided any clarity, detail as to acknowledging the validity of the issues raised or what concrete actions are being taken to minimize any negative impacts on the commercial industry or the rationale for maintaining the status quo," Webb says.

Culp hopes that the program will be one that is streamlined and cost-effective so that the CMA tool is widely accepted and used in the market.

"In a perfect world, it would help our members market their advanced energy-efficient products, which is something NFRC also wants," he says.

Lewis has a similar perspective. "Many AAMA residential members are firmly ensconced in the NFRC residential rating and certification program. As the largest NFRC IA, AAMA works closely with the NFRC to ensure the program is properly administered, and that our members have the opportunity to go to a single entity to obtain both the AAMA air-water-structural Gold Label and the NFRC label for thermal performance of residential products," says Lewis. "The architectural/commercial marketplace is an entirely different situation. AAMA has stressed that this marketplace has a viable tool in place-AAMA 507-that currently accomplishes one of the primary CMA objectives: to rate commercial fenestration for thermal performance. AAMA and NFRC should share the same goals: develop a streamlined, easily administered cost-effective program. The members of AAMA firmly believe that competition is the bedrock of American industry. Let each program stand on its own merit; let the marketplace make the choice between NFRC CMA and AAMA 507, or any other program that might emerge."

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