Like It or Not, Here Comes
Program Now Available Nationwide
At long last the National Fenestration Rating Council’s (NFRC) Component
Modeling Approach (CMA) Product Certification Program, which has been
the source of controversy throughout its conception, is being “fully implemented”
as of this month. According to NFRC executive director Jim Benney, that
means that CMA is now fully ready for use in California, where it is among
the requirements for the state’s updated Code of Regulations (Title 24),
and across the country.
CMA was created by NFRC to enable whole-product energy performance ratings
for nonresidential construction projects. According to information from
the organization, the concept behind component modeling is using performance
data from the three primary components that make up a fenestration product
to obtain an overall product performance rating. Those three components
• Glazing: Glazing optical spectral and thermal data from the International
Glazing Database (IGDB);
• Frame: Thermal performance data of frame cross-sections; and
• Spacer: Keff of spacer component geometry and materials.
The CMA software tool (CMAST) is NFRC’s tool for establishing performance
libraries of approved components that can be accessed to configure fenestration
products for a project and obtain a U-factor, solar heat gain coefficient
(SHGC) and visible transmittance (VT) rating for those products. These
ratings are then reflected in a CMA Label Certificate for code compliance.
As Benney explains it, “It allows people who are involved in that industry—glazing
contractors, manufacturers, curtainwall suppliers, frame suppliers, everybody
in the industry—to determine the energy performance of their products
online. It’s all done through simulations, with 24-hour access to a website;
you can also download it through your own computer and work on designing
systems, on creating bids for projects where you know what the opening
The program has been in a “pilot phase” for several months as NFRC works
to train approved calculation entities (ACEs), those manufacturer representatives
who generate a product’s CMA label certificate; train the inspection agencies
(IA) that will approve components before they are available for use in
a label certificate; accredit simulation laboratories to test the components;
and complete aspects of its software tool, such as tying financial tools
to the software that allow users to pay online.
“January 1 is when we expect [the program] to be out the door for use
in California, as that’s when Title 24 becomes required,” Benney says.
The road to finalizing CMA has been met with great resistance from the
commercial glass industry, which has argued loud and long that, among
other things, a program created for standard residential products can’t
be appropriately adapted for a commercial segment that already works to
create the most energy-efficient projects using products custom-made for
the majority of jobs.
Like many fenestration manufacturers in the commercial market, Peerless
Products Inc. in Ft. Scott, Kan., provides all custom systems. “We have
specific models and operation types of window, but each one is made custom,”
says Jason Davis, an engineer with Peerless. “The commercial world is
a lot different than residential; they produce thousands of [a given type
When it comes to CMA, the problem with custom systems is that each system
must be individually tested for certification, a time-consuming—and quite
Others point out that even though the program is supposed to be fully
complete to meet the Title 24 implementation that went into effect on
January 1, there are still some concerns that haven’t been addressed.
“The thing that troubles me that hasn’t been addressed yet is the NFRC
standard window for testing and verification, on which the certificate
is going to be based, is probably not a true indicator of a curtainwall’s
thermal performance,” says Chuck Knickerbocker, curtainwall manager for
Technical Glass Products in Snoqualmie, Wash. As he explains, “In the
real world, a curtainwall can’t be modeled for thermal performance in
an 80- by 80-inch window. As the percentage of glass goes up on a curtainwall,
as compared to the NFRC model, that typically improves the thermal performance.
“What happens when you can’t get certified—but your real-world model performs
better than the NFRC-modeled test window?” he asks.
Another question that has been repeatedly asked is who NFRC means to be
the “responsible party” for certification.
“[Glazing contractors] need to determine as early as possible who the
‘responsible party’ is for the specific project. This means the party
responsible to obtain the label certificate. It could be the architect,
contractor or manufacturer depending on the project,” says John Kolbeck,
part of Wausau Window and Wall Systems’ research and product development
“In all likelihood the general contractors aren’t going to be the one’s
supplying it. The architects aren’t. That leaves the glazing subcontractors.
If it’s in the specifications then the glazing subcontractors better be
paying attention to it because they’re going to be the ones that in all
likelihood are going to be responsible for getting the certifications,”
On the University of California-Berkeley’s Li Ka Shing Center for Biomedical
and Health Sciences, a five-story, 200,000-square-foot facility that is
part of the CMA pilot phase, achieving the NFRC certifications was “completely
up to” the manufacturer, says Mike Powell, project manager for CS Erectors.
The San Ramon, Calif.-based glazing contractor has been working with Wausau
Window and Wall Systems on certification for this project—a first for
both parties—for more than a year.
As Powell explains, the certifications should be among the submittal documents
provided to the general contractor, who then submits them for architect
and owner review and approval.
“CS Erectors as the installer wouldn’t be able to provide [the NFRC certifications]
so we went directly to Wausau …”
For this specific project, Wausau had to certify a custom unitized curtainwall
system and a standard aluminum window system.
“As of now they’ve provided the windows and they’re working on the unit
wall certification,” Powell says. He explains, “The reason why it’s taking
longer for the unit wall is they actually had to do … some lab testing
to get the certification for this job for the specific system that we’re
using. Everything’s supposed to be completely tested and up on NFRC’s
site so that it’s certified by mid-January.”
Other manufacturers might not be so willing to take on that responsibility.
As Knickerbocker says, “[TGP will] qualify our bid that we’re not going
to be the responsible party for getting this certification.”
The reason this responsibility is such a big issue is that the certificate
of occupancy will rest on the shoulders of the “responsible party.”
“The certificate of occupancy where the owner moves into the building
is going to be contingent upon the NFRC certification,” Knickerbocker
says. “You’re asking for the glazing subcontractors to all of a sudden
take on the building owner’s risk of being able to get a certificate of
occupancy when they have never been in that situation before—that could
be a big deal as the project is winding down.”
That is a big deal—as is the time to get the certification. Timing, Powell
says, is likely the biggest obstacle glazing contractors beginning to
use CMA will face. He advises others to be aware of the time requirements
and start working toward certification as early as possible. “I would
say the sooner the better in terms of getting the ball rolling with the
[manufacturer]. If we could get them going once the contract is awarded
or, really, once you see it in the specifications—you’re not going to
get around it …” he says.
The update of California’s Title 24 approved the use of CMA to determine
energy-related performance ratings for site-built fenestration in nonresidential
“It’s for all site-built or site-glazed or field-glazed buildings that
require CMA, or you can use the default values,” Benney says of the update.
“Obviously you don’t have to use CMA, but if you want to get full credit
for your systems and how they perform you need to use CMA.”
Whether or not they agree with the program, some manufacturers are slowly
beginning to enter products into the libraries so as to be ahead of their
“We’re looking to get into it,” admits Knickerbocker. “If we sell work
in those three territories or it’s coming online, obviously
we want to be in front of that curve, but it’s a work in progress.”
“At Peerless, we’re starting the process of doing the necessary validation
testing,” says Davis. “Once that’s done we’re going to be getting all
of our frame components in [the libraries].”
Manufacturers also are beginning to train ACEs through what Kolbeck says
is a relatively simple process. “Since I was already familiar with the
THERM 5.2 software, my training consisted of a full day of NFRC training
for the CMA software tool with an in-class exam, as well as an online
examination that required successful completion before I earned my ACE
Certification of standard products, at the very least, could help manufacturers
better promote the efficiency of their products to architects but may
also be important should the program gain traction nationwide.
“While currently only mandated in California and Washington, we foresee
nationwide adoption of NFRC label requirements in the future,” Kolbeck
“It’s showing up in specifications we see from across the country that
you need NFRC certification,” Knickerbocker says. “California, Washington
and Nevada seem to be on the front line.”
Ready or Not
While concerns may still echo across the glazing industry, industry professionals
soon will learn firsthand the advantages, and potential shortcomings,
Having lived through the years of disagreements and compromises, Benney
knows there will continue to be some resistance to the program.
“I think there is concern within the industry because it’s going to change
how they do business,” Benney says. “It doesn’t mean it’s bad, it just
means change and change is always difficult in any industry. We believe
it will be a really good force for change in that everybody will now be
able to play on the same level field and know that they can compare products
be able to compare their systems against other folks in a fair and accurate
And as the program gets underway, changes likely will occur.
“We know with software once it gets used more and more you’re going to
find people who want to make enhancements to it. We’re already getting
comments, from our labs and from some of our users, they’re saying ‘hey
the next version should have this enhancement or this use.’ … But obviously
we don’t want to change anything right away.”
Those who are beginning to use the product certification program remind
others that some patience is needed when learning any new system.
“As with any implementation of new codes or software there is a learning
curve involved,” Kolbeck says.
“Be patient,” Davis stresses. “This is a new approach to things, so patience
would be something to keep in mind as everybody works to get through the
first year. I’m sure there’s always going to be some issue that comes
Patience may be key, but many will be waiting anxiously to see if the
predicted holes might appear in the months ahead.
As Knickerbocker says, “I hope I’m wrong, but for this thing coming online
it seems like there are a lot of holes to fill.”
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