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."
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
"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.
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
"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
"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
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