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Building Owners Could Soon Face Fenestration Surcharges
Despite Industry & Committee Opposition, NFRC Board Appears to be Moving Forward With Nonresidential Testing and Certification Program

By Max Perilstein, Arch Aluminum and Glass Company, Inc.

The National Fenestration Rating Council (NFRC) spring meeting recently concluded in San Diego, where the NFRC’s proposed nonresidential rating program, including testing and certification steps, took center stage. Despite strong opposition from several significant members of the glass and glazing industry and without committee support, the NFRC Board appears to be moving forward with its proposed program plans. If the new rating system takes effect, building owners could see thousands of dollars added to the cost of each building.

Program Advances. In 2005, the NFRC Board proposed a nonresidential fenestration initiative and component modeling system to provide commercial buildings with reliable energy efficiency calculations for fenestration products. Under its proposed program, the NFRC would have various computer laboratories develop a computer modeling program that will generate whole system energy calculations for commercial projects. The NFRC would then require testing and on-site certification of every glazing system installed in commercial buildings. While industry members support the development of a whole system energy calculation, they have expressed concerns that testing and certification are redundant and only add unnecessary cost to the program.

After its introduction, the Board sent its proposed nonresidential program to a committee, where it was sent to a subcommittee and task group. Based on testimony from scientists and industry technical experts, all of whom agreed that a component modeling software would produce statistically accurate calculations, a consensus was reached in both the task group and subcommittee to remove the testing and certification steps from the nonresidential rating program. However, because it is a 501(c) 3 organization, the NFRC Board has the power to disregard all input from members and committees.

Despite the recommendations of the task group, subcommittee and industry members and experts, the NFRC Board and Board Ex Officio’s, which is comprised of several individuals who their living in the testing and certification businesses, appears to be moving ahead with implementing the nonresidential program it originally proposed, complete with testing and certification requirements.

Concerns Remain. As the NFRC appears to be ready to proceed with its nonresidential program, the cost to the building owner is a serious matter.

The commercial fenestration industry is not opposed to the development of an energy rating system. On the contrary, the industry is united in its support for an energy rating system, but one that is cost effective, efficient and free from redundant testing and excessive costs and fees. Recent technological advancements have enabled affordable component tests and simulations (the first step of the NFRC-proposed plan) to be extremely accurate, making expensive and redundant physical testing unnecessary. Testing and certification add nothing to building performance, but they do add significant cost.

The NFRC has disregarded input on this program from industry members and experts, publicly stating that, as a 501(c) 3 organization, it has a responsibility to do what is best for consumers, not industry members. However, while the responsibility for conducting the proposed testing and certification will fall on architects or glazing contractors, it will be the consumers – building owners and their tenants – who will ultimately bear the significant costs associated with the program. Industry members are now questioning how adding redundant steps and unnecessary time and expense to a project are in the best interest of consumers.

A longtime proponent of energy-saving building techniques, the fenestration industry also remains concerned that these added costs will have a negative impact on overall building energy performance. If building owners are forced to pay significant amounts of money for this single component of a building, other energy-enhancing features may be set aside, causing a decrease in overall building energy efficiency. Simply said, codes would be met, not exceeded because the cost of just meeting the code with this new proposed program would force building owners into decisions about areas of cost they can control.

Many members of the glass and glazing industry remain concerned that its industry insight and the technical expertise of its members are going unheeded. The NFRC Board has kept fenestration industry representation on the board to a minimum. Currently, out of 23 members of the NFRC Board and Board Ex Officio’s there are no members that have a majority of their business in commercial Storefront, Curtainwall and Glazing. At the same time, a significant percentage of current NFRC Board members continue to earn their incomes from the post-modeling testing and certification processes.

How the current proposed program could affect building owners. There are multiple levels of costs that building owners will incur under the proposed system: 1. When glazing material is to be ordered, the glazing contractor must enter into a license agreement with NFRC (cost to be added to job). 2. The glazing contractor will hire NFRC accredited agency to certify the performance values of the products they are using (cost to be added to job). 3. After certifications come back, the glazing contractor will hire a separate NFRC agency to validate those numbers (cost added to the job). 4. When the job is installed, the Glazing contractor will hire a NFRC Inspection Agency to verify the proper materials were installed (cost added to the job). 5. During construction, certification labels will be affixed and removed on every opening (cost added to the job).

Opponents’ Proposal. Opponent of the proposed NFRC system advocate a more streamlined process. Under the proposed system, anyone meeting a fenestration code will also have the added burden to enter into any license agreement. One certification of the performance numbers should easily suffice, especially when the computer simulations have proven extremely accurate over the years. From there normal construction activity should take place. If the architect or other interested party has an issue, there are successful and time proven remedies, legal and otherwise that are viable options. Industry observers continue to advocate a simple and cost effective process. Proponents of the NFRC plan may argue that computer modeling” does not meet a third party verification threshold,” but computers are remarkably reliable, and at the end of the day, unbiased.

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