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					          Comments on PCP Informational Draft- By Section                                                                                         *             Description for Comment #
                                          CGC = Greg Carney, MKW = Margaret Webb , JS = Joel Smith, DCC = Charlie Curcija,            PM                Being developed by separate committee - Technical committee
                                          = Patrick Muessig, TGR = Tracy Rogers , MF = Marcia Falke, NK =Noel King , TG = Tim                     1
                                          Gehling, TDC = Tom Culp, MT = Mike Turner, TK = Tony Kamber, GLC = Gary Curtis                                Not consisten with the flow chart. Not editorial and to be resolved by
                                                                                                                                                  2     ballot

                                                                                                                                                  3     Policy issue- NFRC BOD

                                                                                                                                                  4     Persusive and Editorial


 #        Commentor Category    Section                                             Comment                                                      Type                      Resolution of Comment
          CGC 5/22     Neg     1.1        Third paragraph calls for " … an NFRC approved Calculation Entity ("ACE") for the calculation NP              1-LAP
                                          of the fenestration system energy indices for which NFRC certification is required …" however,
                                          the details of what is required for NFRC-Approval" has not been defined. Once the glass,
                                          spacer and frame databases have been fully developed, we do not believe the use of the
                                          performance calculation will be a difficult task and therefore, the approval process should be
                                          minimal in terms of training and cost. Individuals not interested in serving as an "NFRC-
                                          Approved Calculation Entity" should be allowed to use the software and databases for design
                                          considerations that may or may not lead to product/project certification. (NOTE: Reference to
                                          the NFRC_Approved Calculation Entity also appears in numerous other sections of the draft
                                          and therefore must be furthered defined.)

      1
          CGC 5/22     Neg     1.1        Last paragraph notes "Products for which label certificates are issued shall be recorded in the   NP          2
                                          NFRC Certified Products Directory." Question: Once "products" are listed, can that product
      2                                   construction be used for multiple projects by multiple parties?
          CGC 5/31     Neg     1.1        Deleted "The Calculation Entity shall be approved by NFRCto use the Component Library". An NP                 1-LAP
                                          NFRC- Calculation Entity shall calculate the values for the fenestration system using NFRC-
                                          (COMMENT: The "procedures" have not been defined.) procedures and the component library
                                          database. (COMMENT: The approval process has not been defined. See above comment
      3                                   regarding use of the software.)
          JS 4/20      N/A     1.1        {{Terminology includes Components-Based Fenestration Product Certification Program,    Editorial
                                          Components-Based Non-Residential Product Certification Program, Components-Based Whole
                                          Product Certification Program, and Components-Based Fenestration Product Program. This
                                          needs to be standardized according to the input from the committee.}}
      4                                                                                                                                                 4
      5 MF 5/22        Neg     1.1        3rd paaragraph - product certification AUTHORIZATION under ….                                     Editorial   4
        TK 5/22        Neg     1.1        The product certification withstanding, use of the component library should be open to those NP               2
      6                                   who wish to use it.
        CGC 5/31       Neg     1.3        Approved Component Laboratory - (QUESTION: Does this mean that NFRC intends to create a NP                    2
                                          replacement for the International Glazing Database developed and maintained by the Windows
      7                                   and Daylighting Group at LBNL?)
      8 CGC 5/31       Neg     1.3        Commercial Fenestration systems - added sloped glazing systems                                    P           4
        CGC 5/31       Neg     1.3        Fenestration - : (COMMENT: The official NFRC definition should be provided in this                P           4 - Defination from NFRC Glosarry
      9                                   document!)
     10 CGC 5/31       Neg     1.3        Glass - (COMMENT: Insert the definition from the other NFRC document.)                            NP          2
     11 CGC 5/31       Neg     1.3        Deleted - Laboratory Accreditation Program definition.                                            NP          2
     12 CGC 5/31       Neg     1.3        Deleted - NFRC Inspector                                                                          NP          2
     13 CGC 5/31       Neg     1.3        Product - (COMMENT: Insert the definition from the other NFRC document(s).)                       NP          2
     14 CGC 5/31       Neg     1.3        Product Line - (COMMENT: Insert the definition from the other NFRC document(s).)                  NP          2



NFRC CMA-PCP
Informational Draft Comments                                                64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                             Page 1
        CGC 5/31     Neg             Project Certificate - deleted - The project certificates list the average energy rating values for   NP   2
   15                          1.3   these labeled fenestration systems.
   16 CGC 5/31       Neg       1.3   Deleted - Simulation                                                                                 P    4
      CGC 5/31       Neg       1.3   Total Fenestration Product - (COMMENT: Insert the definition from the other NFRC                     NP   2
   17                                document(s).)
   18 DCC 4/20       N/A       1.3   Definitions should be included in the Glossary and Terminology document, not here.                   NP   2
   19 DCC 5/22       ???       1.3   Definitions should be included in the Glossary and Terminology document, not here                    NP   2
      GLC 2/23       N/A       1.3   Discussion needs to be held regarding the testing requirement of the Component Based Non-            NP
   20                                Residential Product Certification Program.)                                                               2&3
   21 MF 5/22        Neg       1.3   Design Evaluation.                                                                                   NP   2
   22 MF 5/22        Neg       1.3   Need to add EXPERT REVIEWER.                                                                         P    4 - Need to develpe an definition
   23 MF 5/22        Neg       1.3   Lineal Supplier:: Remove one colon.                                                                  p    4
        MKW 4/6      N/A       1.3   {doors} This seems to be a definition for fenestration products including residential and            NP
   24                                commercial.                                                                                               2
        MKW 4/6      N/A       1.3   {Specifying Authority} This definition is too narrowly defined and is in the wrong place under       NP   2 - add manufacturer, glazing contractor, suppliers, project
   25                                Definitions.                                                                                              manager.
   26 MKW 4/6        N/A       1.3   {family} What is the point of this definition?                                                       NP   2
      MKW 4/6        N/A       1.3   {Comment on Testing} We have had this discussion already. See previous meeting notes               NP
                                     from Non Residential Task Group. The reason the flow chart does not include testing is
                                     deliberate not as a result of not being discussed. Testing will drive up the cost of this program!
   27                                                                                                                                          2
   28 MKW 4/6        N/A       1.3   {peer review} Should there be a definition for Expert Review as well?                                p    4 - see #C22
   29 MKW 4/6        N/A       1.3   {product} This isn’t a definition. It doesn’t provide clarification on the term.                     NP   2
   30 MKW 4/6        N/A       1.3   {product Line} This isn’t a definition. It doesn’t provide clarification on the term.                NP   2
   31 MKW 5/22       Neg       1.3   Approved Component Library: I believe the glazing library is the property of LBNL.                   NP   2
   32 MKW 5/22       Neg       1.3   Approved Calculation Entity: See comment on section 1.2.5 and general comment.                       NP   1 - LAP
   33 MKW 5/22       Neg       1.3   Family: What is the purpose of this definition.                                                      NP   2 - see # 26
   34 MKW 5/22       Neg       1.3   Person: What is the purpose of this definition.                                                      NP   2
   35 MKW 5/22       Neg       1.3   Specifying Authority: Should not be limited to architects and engineers.                             NP   2 - see # C25 & 68
        MT 5/22      Neg       1.3   Approved Calculation Entity - By requiring an ACE to meet NFRC requirements of the LAP, I            NP   1&2
                                     believe you are limiting the ACE to be an Accredited Laboratory or Simulator. This is not
   36                                acceptable.
        MT 5/22      Neg       1.3   Quality Control Auditor - Since the Specifying Authority definition is restricted to Architects,     NP   2
                                     Specifiers, and Project Engineers, I don't believe the SA would be able to provide this type of
   37                                assurance.
   38 MT 5/22        Neg       1.3   Specifying Authority - Too restrictive, see earlier comment.                                         NP   2 - see # C25 & 68
      TDC 5/22       Neg       1.3   Definitions                                                                                          NP   2
                                     • Editorial changes.
   39                                • Unused terms deleted.
        TGR 5/22     Neg       1.3   Glazing Contractor (editorial): Should consider adding "commercial" before "… fenestration           NP   2
   40                                system" to clarify the intent.
        TGR 5/22     Neg       1.3   Manufacturer: As there is no definition of a "fenestration product" there may be confusion           NP   2 - resolve by providing def. of fenestration
                                     between this entity and a Glazing Contractor as it pertains to products assembled at a product
                                     site. Clarification is required to differentiate between K-D type "products" that are assembled
                                     on site from a "manufacturer" versus site-built products/systems that are assembled by the
                                     glazing contractor and/or sub-contractors.
   41




NFRC CMA-PCP
Informational Draft Comments                                             64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                       Page 2
        TGR 5/22     Neg       1.3   Spacer, Spacer System, Spacer Manufacturer: Who is responsible for corner keys, connectors NP          2- Hardware is not modeled
                                     and the sort? These must be included in the thermal analysis yet, by these definitions, they do
   42                                not exist.
        TGR 5/22     Neg       1.3   Certification: From where did Physical Testing and/or Non-Validation come? As noted in the       NP    2 - see # C27
                                     comment, discussion needs to be had re: the need for and means of testing commercial
                                     fenestration systems. Until this is had and agreed to, this section should be deleted.
   43
   44 MKW 4/6        N/A       2.2   Hard to approve this language when the procedure has not been written                            NP    1 - Technical committee (Tech. C)
      DCC 5/22                 2.3   Added - D. Frame systems can be subject of grouping rules, as detailed in NFRC 100.              NP    2
                                     Grouping category shall be indicated for framing systems that are grouped. E. After the IA has
                                     approved framing system, it is automatically assigned # sign indicating approved status.
   45
   46 DCC 5/22       ???       2.3   Deleted rest of section                                                                          NP    2
      JS 4/20        N/A       2.3   A framing system may be granted NFRC approval for inclusion into the Components Library by NP          2&3
                                     complying with either the procedure of section 2.3.1 or the procedure of section 2.3.2:
                                     2.3.1 Framing system categories with default performance values
                                     A. A framing system may be assigned to the appropriate generic framing system category from
                                     the list below, and use the default performance values associated with that category.
                                     [Placeholder for future list of frame system categories and the associated default performance
                                     values. Alternately, refer to a new technical document, NFRC 304, which contains this
                                     information.]
                                     B. The manufacturer or supplier of the framing system shall provide system assembly drawings
                                     and material specifications to NFRC, along with the recommended frame system category.
                                     C. NFRC shall confirm the appropriate frame system category, and enter the framing system
                                     information into the Approved Components Library.




   47
        MT 5/22      Neg       2.3   Sim labs should submit to an IA … remove sections C & D. New framing grouping rules must         NP    2 -Note define Expert reviewer
                                     be defined before this program can be approved. What will be the anticipated time it takes to
   48                                get data into the library?
        TDC 5/22     Neg       2.3   Framing System Approval                                                                           NP   2&3
                                     • The ability to use default frame categories and default performance values without simulation
                                     is essential for minimizing complexity, especially for custom extrusions which may only be used
                                     once. Language added to clarify the two options: default categories without simulation, or
                                     detailed simulation by a sim lab. Some argue that this issue should be ignored until the
                                     categories have been developed, but it does affect the PCP process, and it is important enough
                                     to include the framework now.
                                     • Some (but not all) manufacturers have expressed concern about peer-review and the potential
                                     to expose some trade secrets. Use of an IA is acceptable when doing simulations, as long as
                                     the ability to use default categories without simulation is also preserved. On the other hand, an
                                     IA may not even be necessary if an independent sim lab is used.

   49
        TK 5/22      Neg       2.3   Deleted entire section and reworded. Added "A framing system may be granted NFRC                 NP    2&3
                                     approval for inclusion into the Components Library by complying with either the procedure of
   50                                section 2.3.1 or the procedure of section 2.3.2."




NFRC CMA-PCP
Informational Draft Comments                                          64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                  Page 3
        TK 5/22      Neg       2.3   Added 2.3.1:                                                                                 NP            2&3
                                     A. Aframing system may be assigned to the appropriate generic framing system category from
                                     the list below, and use the default performance values associated with that category.
                                     Placeholder for future list of frame system categories and associated default performance
                                     values. Alternately, refer to a new technical document, NFRC 304 which contains this
                                     information.
                                     B. The manufacturer or supplier of the framing system shall provide system assembly drawings
                                     and material specifications to NFR, along with the recommended frame system category.
                                     C. NFRC shall confirm the appropriate frame system category, and enter the framing system
                                     information into the Approved Components Library.


   51
        TK 5/22      Neg       2.3   Added 2.3.2:                                                                                  NP           2
                                     A. An NFRC accredited simulation laboratory shall calculate the framing system values in
                                     accordance with NFRC technical procedures using information submitted by the framing
                                     system manufacturer. The information submitted includes, but is not limited to:
                                     i system assembly drawings/shop drawings
                                     ii system die drawings
                                     iii glazing bite
                                     iv bill of materials
                                     B. The NFRC accredited simulation laboratory shall create framing system models using NFRC-
                                     approved software tools
                                     C. Multiple framing systems may be subject to frame grouping rules where the grouped
                                     products shall use the performance values of the simulated frame group leader.
                                     Placeholder for future frame grouping rules. Alternately, refer to a new technical document,
                                     NFRC 304 which contains this information.
                                     D. The NFRC accredited simulation laboratory shall submit a report to the NFRC licensed IA
                                     chosen by the framing system manufacturer in accordance with the NFRC LAP.
                                     E. The NFRC licensed IA shall review all submitted information for accuracy and once approved
                                     enter the framing system(s) into the Approved Component Library.



   52
        MT 5/22      Neg       3.1   See earlier comments on SA. Is the "label certificate" described in C different than the "official    NP   2
   53                                label certificate" defined in D?
        TDC 5/22     Neg       3.1   Specifying Authority Obligations                                                                      NP
                                     • IA only audits a randomly selected fraction of product ratings, so language changed to reflect
                                     that.
                                     • Changed time to provide documentation to 15 days after notification of the audit.
                                     • IA not necessary to review whole-product rating calculation, issue CAR, or issue label
   54                                certificate. These can be done directly by ACE.                                                            2
        DCC 4/20     N/A       3.2   ACE only needs to know how to use NRFEN, not other NFRC-approved software tools, like                 P    4 - add 'appticable' before approved.
   55                                THERM or WINDOW.
        DCC 5/22     ???       4.1   Replaced - approved component ratings from a component based library database and                     NP
   56                                additional software tools with NRFEN                                                                       1&2
        GLC 2/23     N/A       4.2   The first thing we should talk about is what products are eligible, then how you do it, who does it   NP   2
   57                                and then the label/label certificate…
        DCC 4/20     N/A       4.3   This has all been spelled out completely in Section 2. Why would we repeat it here, other than        NP   2
   58                                trying to confuse ourselves?
   59 CGC 5/31       Neg       5.1   (COMMENT: See earlier comments regarding the documentation trail and audits.)                         NP   1,& 2
   60 DCC 4/20       N/A       5.1   Welcome to the 21st century! Lets skip “paper-trails” and establish “electronic-trails”.              NP   2




NFRC CMA-PCP
Informational Draft Comments                                            64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                        Page 4
                                                             st
   61 DCC 5/22       ???       5.1       Welcome to the 21 century! Lets skip “paper-trails” and establish “electronic-trails”]                NP   2
   62 MKW 5/22       Neg       5.1       The documentation trail requirements need to be established.                                          NP   1
        TDC 5/22     Neg       5.1       Documentation-Trail Audit                                                                             NP   2
                                         • Clarified that only a fraction of product certificates are selected for audit.
                                         • Removed notification of code official. Although I agree one major purpose of NFRC rating is
                                         for code use, it is not the role of an IA to get into direct enforcement. It may also be a waste if
                                         the project is still at an early phase and the specifying authority takes corrective action.
   63
        DCC 4/20     N/A       5.2       I don’t understand why would specifying authority be responsible for audit costs. I think that        NP   2,&3
                                         audit costs should be built inot the program cost and charged once through the certificate fee.
   64                                    This way it increases bureaucracy.
        DCC 5/22     ???       5.2       I don’t understand why would specifying authority be responsible for audit costs. I think that        NP   3
                                         audit costs should be built inot the program cost and charged once through the certificate fee.
   65                                    This way it increases bureaucracy
        MT 5/22      Neg       5.2       Auditing expenses should be built into the ACE licensing agreement with NFRC. Random                  NP   2&3
                                         samplings can be done on their certified projects. The market will not support Sas being
   66                                    responsible for paying for random audits.
        TDC 5/22     Neg       5.2       Expenses                                                                                              NP   3
                                         • Because only a fraction are audited, the costs should be spread out through the overall
                                         program fees, not borne by the Specifying Authority who happened to get picked.
   67
        GLC 2/23     N/A       6.0       (Comment: This section needs to be rewritten to fit the component based program and the Role          NP   2 - add manufacturer, glazing contractor, suppliers, project manager
   68                                    of the Design Professional .)                                                                              - Gary to review.
        MKW 5/22     Neg       6         This whole section is over written and unnecessarily bureaucratic. It does not need to be this        NP   2
   69                                    complicated in order to document the challenge procedures.
        MKW 4/6      N/A       6.1       This section is over-written and difficult to follow. It seems excessively bureaucratic. I believe    NP   2
   70                                    the process can be described in much simpler terms.
        TDC 5/22     Neg       6.2       Right to Challenge                                                                                    NP   3
                                         • Language change that IA not necessary to issue certification. These can be done directly by
   71                                    ACE.
        TDC 5/22     Neg       6.3       Challenge Procedure                                                                                   NP   2
                                         • Since an IA did not issue the specific label certificate, changed language to just make it
                                         general that any IA is used for the challenge process.
   72                                    • Editorial changes
        GLC 2/23     N/A       7.0       (Comment: This section needs to be rewritten to fit the component based program and the Role p             4 - see 72
   73                                    of the Design Professional .)
   74 DCC 5/22       ???       1.1.A     Added system                                                                                 p             4
   75 DCC 5/22       ???       1.1.B     Added assembly                                                                                        p    4
   76 MKW 4/6        N/A       1.1       (what does this mean…”independent NFRC”                                                               NP   1
      MKW 4/6        N/A       1.1       (this is not what the Non residential Task Group agreed to in Atlanta. We agreed to “approved” NP          1
                                         so this entity would not be subject to the same rigorous requirements of accredited entities.
   77                                    See meeting notes from Atlanta, October 5, 2005)
   78 CGC 5/31       Neg       1.2.1.D   (COMMENT: See above comments regarding the approval process);                                         NP   1
   79 MT 5/22        Neg       1.2.1.D   Need to define how NFRC "approves" an "Approved Calculation Entity".                                  NP   1
        TK 5/22      Neg       1.2.1.G   The CPD could also serve as the data base where ratings of previous component                         NP   2
   80                                    configurations could be accessed on future projects thus
        CGC 5/22     Neg       1.2.2     Third paragraph notes "… an NFRC-licensed fenestration Specifying Authority …" Question:              NP   1
                                         What are the deetails of how someone becomes an NFRC-licensed fenestration Specifying
   81                                    Authority?
   82 MKW 4/6        N/A       1.2.2     Would like to see the hard copy procedure.                                                            NP   1 - check



NFRC CMA-PCP
Informational Draft Comments                                                64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                        Page 5
        MT 5/22      Neg       1.2.2       3rd paragraph - "… and NFRC-licensioned fenestration Specifying Authority" Remove the word p              4 - delete fenestration consistent terminolagy
   83                                      fenestration.
        TDC 5/22     Neg       1.2.2       Role of Specifying Authority:                                                                    p, NP    4,2,1,3,3
                                           • Editorial changes.
                                           • SA does not contract IA to issue label certificate, which can be done by ACE.
                                           • IA only audits a randomly selected fraction of product ratings, so language changed to reflect
                                           that.
                                           • Removed language in section 1.2.2.1 about participating in other certification programs “not
                                           related to energy performance.” Certifying air leakage under AAMA/WDMA/CSA
                                           101/I.S.2/A440 could be considered "energy related" since it is required in IECC and ASHRAE.
                                           This language is not really necessary, anyway.
   84
        CGC 4/12     N/A       1.2.2.1     I honestly do not understand the intent of this item and would ask if Bipin or Carl can explain      NP   2
   85                                      the intent.
   86 CGC 5/31       Neg       1.2.2.1.B   (QUESTION: What does this mean -- what specifically is it attempting to address?)                    NP   2
   87 MKW 4/6        N/A       1.2.2.1.B   {procedures} Is this a restraint of trade?                                                           NP   2
   88 MKW 5/22       Neg       1.2.2.1.B   This appears to be a restraint of trade.                                                             NP   2
      CGC 5/22       Neg       1.2.2.B     Second bullet "Detailed Information on Spacer System." Previous drafts and discussions               NP   2
                                           related to the spacer system information have included the sealant materials and dimensions.
                                           While the information has been removed from this draft, it is likely to return in response to this
                                           review. In order to avoid multiple simulations related to minor variations in the sealant
                                           dimensions (silicone secondary seals for structural silicone glazing applications for example),
                                           we recommend default sealant system (dimensions) be established for the various spacer
                                           systems that are entered into the spacer database.
   89
   90 CGC 5/31       Neg       1.2.2.B     3rd bullet - (QUESTION: What is meant by "Detailed information"?)                                    NP   2
      DCC 5/22       ???       1.2.2.B     Added - in writing and added - and identification of the insulating glass fabricator including       NP   2
                                           name and contact informationafter 1st bullet and added - and spacer manufacturer including
                                           name and contact information after 2nd bullet and added - and identification of the framing
                                           system manufacturer/fabricator including name and contact information after 3rd bullet.
   91
        MKW 4/6      N/A       1.2.2.B     Entity (let’s be consistent. There’s a number of different terms in this document…Approved        p       4
                                           Calculation Entity, Calculation Entity, Approved Calculation Entity, Approved Calculation Entity,
                                           Calculation Entity. Let’s pick something and use it throughout the document otherwise it will be
                                           open to mis-interpretation and could lead to confusion to the reader);
   92
        MKW 4/6      N/A       1.2.2.B     This can be provided by the IG manufacturer along with the other information requested.. I           NP   2
   93                                      don’t see the need to list it separately.
        MT 5/22      Neg       1.2.2.B     Need to develop a clear, consise form for the person responsible for submitting this                 NP   1
   94                                      documentation. Reference it as an Appendix attachment.
        TK 5/22      Neg       1.2.2.B     Deleted specific requirements - added "Component information required for the software to            NP   2
   95                                      perform the calculation."
   96 MF 5/22        Neg       1.2.2.C     Requires IG certification.                                                                           NP   2
   97 TK 5/22        Neg       1.2.2.C     Deleted.                                                                                             NP   2




NFRC CMA-PCP
Informational Draft Comments                                                  64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                Page 6
        CGC 5/22     Neg       1.2.2.D     Provides the first reference to the "… whole product rating specification data retention     NP          1&2
                                           (Documentation Trail) …". The requirements of the documentation trail and individual project
                                           requirements have yet to be defined. As we have mentioned in numerous previous meetings,
                                           the contractural nature of the commercial construction industry and well established
                                           documentration requirements of purchase orders, acknowledgements, shipping case tags, etc.,
                                           are an ongoing part of the commercial fenestration industry. The subcommittee needs to
                                           carefully consider the requirements of the documentation trail. We strongly recommend a
                                           minimal audit program where a small percentage of projects require submittal of a limited
                                           number of defined documents. (NOTE: The documentation trail is mentioned in several
                                           sections of the draft and needs to be properly discussed and defined before the product
                                           certification program moves forward for adoption.)

   98
        DCC 4/20     N/A       1.2.2.D     I disagree that there is a need for IA for whole product certification. I believe that it is much   NP   2&3
                                           more cost-effective and less cumbersome if random selection of whole product
                                           certifications/label certificates are reviewed by IAs on an annual basis, while ACE is allowed to
   99                                      issue label certificate in real-time from the component library.
        DCC 5/22     ???       1.2.2.D     I disagree that there is a need for IA for whole product certification. I believe that it is much   NP   2&3
                                           more cost-effective and less cumbersome if random selection of whole product
                                           certifications/label certificates are reviewed by IAs on an annual basis, while ACE is allowed to
  100                                      issue label certificate in real-time from the component library]
  101 TK 5/22        Neg       1.2.2.E     Deleted.                                                                                            NP   2
      CGC 5/22       Neg       1.2.2.F     Last paragraph reads "Additional requirements may be established by NFRC as necessary to         NP      2
                                           assure continued program credibility." In lieu of such an open ended statement at this location,
                                           we would recommend a general statement in the Forward stating that program requirements
                                           may be modified at times based on committee and membership actions.
  102
        TK 5/22      Neg       1.2.2.F     Deleted - Additional requirements may be established by NFRC as necessary to assure                 NP   2
  103                                      continued program credibility.
        TDC 5/22     Neg       1.2.3       Role of component manufacturers                                                                     NP   3
                                           • Added note that any manufacturer may qualify as an ACE, similar to the language in section
  104                                      1.2.6 for sim labs.
  105 TK 5/22        Neg       1.2.3       This needs to be definitive in terms of the definition of the role.                                 NP   2
  106 TK 5/22        Neg       1.2.3       This needs to be definitive in terms of the definition of the role.                                 NP   2
  107 TK 5/22        Neg       1.2.3       Deleted - including but not limited to the following functions.                                     NP   2
      DCC 4/20       N/A       1.2.3.2     I have deleted most of peer review, expert review by certified simulators, etc. tasks as         NP      2
                                           unnecessary and complex. It is far more effective to have certified simulator perform simulation
                                           and upload information and be done with it, rather than developing the whole new Rube
                                           Goldberg type of process, where there are additional layers of bureaucracy and oversight.
  108
  109 DCC 5/22       ???       1.2.3.2     Deleted C, D & E - This is not the place to describe details of spacer grouping                     NP   2
  110 MF 5/22        Neg       1.2.3.2     Peer review for spacer's info into bucket.                                                          NP   2
        DCC 5/22     ???       1.2.3.2.B   Revised to read - Submitting spacer details to the certified simulators to simulate their                2
  111                                      performance for upload to the NFRC approved component database.                                     NP
        DCC 5/22     ???       1.2.3.2.B   Revised to read - Note: the spacer information excludes sealants. Appropriate sealants are          p    4
                                           specified during the IGU component definition using approved NFRC software tool.
  112




NFRC CMA-PCP
Informational Draft Comments                                                   64591064-c170-4c11-a8e0-572654ca4c69.xls                                   Page 7
        DCC 5/22     ???       1.2.3.2.B    I have deleted most of peer review, expert review by certified simulators, etc. tasks as        NP       2
                                           unnecessary and complex. It is far more effective to have certified simulator perform simulation
                                           and upload information and be done with it, rather than developing the whole new Rube
                                           Goldberg type of process, where there are additional layers of bureaucracy and oversight.]
  113
        GLC 2/23     N/A       1.2.3.2.B   (Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. Isn’t     NP   2
  114                                      this the responsibility of the simulator?)
        GLC 2/23     N/A       1.2.3.2.C   (Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. This is   NP   2
  115                                      the responsibility of NFRC.)
        MKW 5/22     Neg       1.2.3.2.C   Spacer peer review rules have not been developed. Cannot approve a document that has                 NP   1
  116                                      procedures that still need to be developed.
        GLC 2/23     N/A       1.2.3.2.D   (Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. This is   NP   2
  117                                      the responsibility of NFRC.)
        GLC 2/23     N/A       1.2.3.2.E   (Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. This is   NP   2
  118                                      the responsibility of NFRC.)
        CGC 4/12     N/A       1.2.3.3     Beginning with this section and continuing throughout the draft, I do not believe the information    NP   2
                                           on the framing considerations have properly addressed the task group flow chart or the text
  119                                      provided by Joel Smith and Tony Kamber.
        CGC 5/22     Neg       1.2.3.3     The subcommittee needs to develop/finalize the spacer grouping rules before this certification       NP   1
  120                                      program moves forward for adoption.
  121 DCC 4/20       N/A       1.2.3.3     This is not the place to describe details of spacer grouping.                                        NP   2
  122 MF 5/22        Neg       1.2.3.3     Group Keff for spacers.                                                                              NP   1
        MKW 5/22     Neg       1.2.3.3     Spacer grouping rules have not been developed. Cannot approve a document that has                    NP   1
  123                                      procedures that still need to be developed.
        TGR 5/22     Neg       1.2.3.3     There exists no approved mechanism for grouping spacers at this time. There is an                    NP   1
                                           assumption that a viable option exists but, for the purposes of having a complete operational
  124                                      document, this remains an assumption and the section is invalid.
        GLC 2/23     N/A       1.2.3.3.A   (Comment: There are hundreds of thousands if not millions of possible framing system pieces NP            1
                                           and/or parts that can be used on commercial window walls, curtain walls, and skylights. It is not
                                           feasible to expect framing system suppliers to be subjected to the cost for modeling of all of the
  125                                      possible component parts.)
  126 MKW 4/6        N/A       1.2.3.3.D   {review} Peer or expert?                                                                             NP   2
      MKW 4/6        N/A       1.2.3.3.F   {[*language in square bracket is suggested task group language not in the flow chart ]} I            NP   2 - deleted no longer in the document.
                                           support the inclusion of this clause. Provides independent in the selection procedures.
  127
        CGC 5/22     Neg       1.2.3.4     A framing system manufacturer should have the right to simulate framing systems in-house and NP           2&3
  128                                      then have the work checked by an accredited simulator.
        CGC 5/31     Neg       1.2.3.4     Added - F. Choose to use only component product databases and simulation tools under the      NP          2 & 3 - needs to be after certification section.
                                           NFRC program for design evaluation without the intent of product or project certification and
  129                                      labeling.




NFRC CMA-PCP
Informational Draft Comments                                                 64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                   Page 8
        TDC 5/22     Neg       1.2.3.4      Role of Framing Manufacturer:                                                                       NP     3
                                            • Also see section 2.3. The ability to use default frame categories and default performance
                                            values without simulation is essential for minimizing complexity, especially for custom
                                            extrusions which may only be used once. Language added to clarify the two options: default
                                            categories without simulation, or detailed simulation by a sim lab. Some argue that this issue
                                            should be ignored until the categories have been developed, but it does affect the PCP
                                            process, and it is important enough to include the framework now.
                                            • Also see section 2.3. Some (but not all) manufacturers have expressed concern about peer-
                                            review and the potential to expose some trade secrets. Use of an IA is acceptable when doing
                                            simulations, as long as the ability to use default categories without simulation is also preserved.
                                            On the other hand, an IA may not even be necessary if an independent sim lab is used.


  130
        TK 5/22      Neg       1.2.3.4      Added "Framing manufacturer may elect to perform the calculation itself and forward for (end?) NP          2 - comment is incomplete
  131
  132 MF 5/22        Neg       1.2.3.4.A    Accredited simulator to do sims not acc lab.                                                          NP   2
  133 MF 5/22        Neg       1.2.3.4.A&D Accredited simulator checks his own work????                                                           NP   2
        MT 5/22      Neg       1.2.3.4.B    I'm assuming this section applied to Product Line Simulations (see section 4.1.H). I don't            NP   2&1
                                            believe "system dimensional tolerances" is appropriate. Maybe "nominal system dimensions".
                                            Also, what is the procedure for adding a section to a product line? (i.e., adding a 4" wide
  134                                       curtain wall vertical mullion to a standard 2 1/2" curtain wall system.)
  135 TK 5/22        Neg       1.2.3.4.B    Deleted - and shop drawings                                                                           NP   2
      MT 5/22        Neg       1.2.3.4.C    I believe the "simulation model" should match the NFRC default gateway size for that product          NP   2
                                            category. Is this supposed to be provided in the form of an elevation drawing?
  136
        JS 4/20      N/A       1.2.3.4.D    Expert Review.{{Peer review is used in the flow chart but expert review is also used at times, NP          2
  137                                       the committee should select one only.}}
        MT 5/22      Neg       1.2.3.4.D    Delete this section - not necessary. Challenge procedures are in place to handle numbers that NP           2
                                            appear erroneous. The manufacturer has already contracted with an Accredited
  138                                       Laboratory/Simulator to prepare the data.
  139 MF 5/22        Neg       1.2.3.4.E    Conflicts with D of 1.2.4.                                                                            NP   2 - comment not clear
      CGC 5/22       Neg       1.2.3.5      The subcommittee needs to develop/finalize the frame grouping rules before this certification     NP       1
                                            program moves forward for adoption. As we have expressed at numerous meetings, we
                                            strongly believe that the framing system grouping represents a critical element of developing a
                                            product certification program that can be fair, accurate and cost effective. Failure to recognize
                                            the ability to develop framing system grouping and pushing the program forward without this
                                            aspect will dramatically affect the program cost, support, and acceptance by the commercial
                                            fenestration industry.
  140
        MKW 5/22     Neg       1.2.3.5      Frame grouping rules have not been developed. Cannot approve a document that has                      NP   1
  141                                       procedures that still need to be developed.
        MT 5/22      Neg       1.2.3.5      New frame grouping rules need to be developed for the commercial market. It is essential that         NP   1
                                            these rules be developed prior to the approval of this certification program. It is not feasible to
                                            require framing manufacturers to model the thousands of options available within their product
                                            lines. I also believe that default values should be developed. A MFG could choose to use
  142                                       default values or simulate their own.




NFRC CMA-PCP
Informational Draft Comments                                                   64591064-c170-4c11-a8e0-572654ca4c69.xls                                                            Page 9
        CGC 5/22     Neg       1.2.4     We question the role of the IA in the whole product certification based on calculations with        NP   2&3
                                         materials from the databases. Once the glass, spacer and framing system(s) have been
                                         documented in the project specifications, a calculation entity combines the specified products
                                         and framing system and calculates the thermal and optical performance values. The cost of
                                         having the IA check to see if the calculation entity used the specified products in the calculation
                                         is unnecessary. We believe the cost and role of the IA can be dramatically reduced by the
                                         properly designed software using glass, spacer grouping and frame grouping opportunities.
  143
  144 MT 5/22        Neg       1.2.4     Rework per comments on 1.22, 1.2.2.B, 1.2.3.4.B, 1.2.3.4,C, 1.2.3.4.D and 1.2.3.5.                NP     2
      TDC 5/22       Neg       1.2.4     Role of IA                                                                                        NP     3&2
                                         • IA only audits a randomly selected fraction of product ratings, so language changed in multiple
  145                                    places to reflect that.
  146 TK 5/22        Neg       1.2.4     Deleted but not limited to                                                                        NP     2
  147 MF 5/22        Neg       1.2.4.C   Conflicts with E of 1.2.3.4.                                                                      NP     2 - Need to discuss
        CGC 5/31     Neg       1.2.4.D   (QUESTION: Do the current IA's have staff members that are prepared to approve framing            NP     2
  148                                    component performance values?);
        MKW 4/6      N/A       1.2.4.D   {database} I didn’t think IA’s were part of the component approval process. The IA comes into     NP
  149                                    play when certification is required.                                                                     2 - see # C147
        CGC 5/31     Neg       1.2.4.E   (COMMENT: See earlier comments related to the definition of the documentation trail and the       NP     2
  150                                    level of product / project audits);
        MKW 5/22     Neg       1.2.4.I   The IA is not part of the component approval procedure per the Visio Flow Chart identified as     NP     2 - see # C 147
  151                                    Draft IV, November 29, 2005.
        CGC 5/31     Neg       1.2.5     Added - D. Perform component-based fenestration product calculations for design evaluation        NP     2
  152                                    purposes when product/project certification may or may not be intended.
  153 MF 5/22        Neg       1.2.5     Creates ACE.                                                                                      NP     1 - LAP
      MKW 4/6        N/A       1.2.5     {is responsible for meeting the requirements in the LAP and PCP including, but not limited to,    NP
                                         the following functions:} Thought the intent was that the ACE was NOT subject to the LAP.
  154                                                                                                                                             1&2
        MKW 5/22     Neg       1.2.5     (Comment: Need to create requirements for ACE)                                                      NP   1&2&3
                                         This is a substantial issue and will affect the cost-effectiveness and timeliness of the process. I
                                         cannot vote to approve the PCP document in its current form without the development of all
  155                                    requirements.
        TDC 5/22     Neg       1.2.5     Role of ACE                                                                                       NP     2
  156                                    • Included that ACE can directly issue label certificate.
        CGC 5/31     Neg       1.2.5.A   (COMMENT: See earlier comments regarding the approval process, use of the software tool           NP     2
  157                                    and whole product calculations.)
        DCC 5/22     ???       1.2.5.A   Added - software tool, which incorporates Component- Modeling Approach (CMA) and full             p      4 -add 'applicable NFRC approved software and …
  158                                    database solution, further called NRFEN
  159 MKW 4/6        N/A       1.2.5.A   approved (or authorized)                                                                          NP     2
      DCC 4/20       N/A       1.2.5.B   This is not necessary. Independence criteria needs to be maintained only to submit component NP
                                         level data. Manufacturers or any other trained entity should be allowed perform whole product
  160                                    assembly based on approved components.                                                                   2&3
        DCC 5/22     ???       1.2.5.B   Deleted - This is not necessary. Independence criteria needs to be maintained only to submit      NP     2&3
                                         component level data. Manufacturers or any other trained entity should be allowed perform
  161                                    whole product assembly based on approved components
  162 MKW 4/6        N/A       1.2.5.B   See comment on approved versus accredited..                                                       NP     2
  163 DCC 5/22       ???       1.2.5.C   Added - NRFEN                                                                                     NP     2
        MT 5/22      Neg       1.2.5.C   You should not have to be an ACE to utilize the software for preliminary design purposes.         NP     2&3
                                         Framing manufacturers should be allowed to use the software for their own product lines.
  164                                    Component Manufacturers should also be allowed to be an ACE.



NFRC CMA-PCP
Informational Draft Comments                                               64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                 Page 10
        CGC 5/31     Neg       1.2.6     2nd paragraph - deleted - Specifying Authorities and Component Manufacturers participating in NP      2
                                         the NFRC Component-Based Fenestration Product Certification Program shall use accredited
                                         Simulation Laboratories or an accredited Simulator for fenestration system frame modeling
  165                                    files.
        DCC 5/22     ???       1.2.6     2nd paragraph - revised to read - B. Simulating spacers in accordance with NFRC approved         NP   2
                                         programs
                                         C. Inputting framing system and spacer information into the component database, upon the
                                         authorization of the framing and /or spacer manufacturer; including all necessary information,
  166                                    based on which IA can perform appropriate review
        TDC 5/22     Neg       1.2.6     Role of sim labs                                                                                 NP   2
                                         • Removed language for Specifying Authority and component manufacturers that is redundant
  167                                    with previous language in Sections 1.2.2 and 1.2.3.
  168 TK 5/22        Neg       1.2.6     2nd paragraph - deleted - including but not limited to the following functions                   NP   2
  169 TK 5/22        Neg       1.2.6     2nd paragraph - B - deleted to the IA                                                            NP   2
        DCC 4/20     N/A       1.2.6.B   Accredited simulation laboratory shall be responsible only for certified simulations of          NP
                                         components and submission of components to the component database. ACE is responsible
                                         for whole product calculations. This does not preclude accredited simulation laboratories to
  170                                    have ACEs on staff.                                                                                   2&3
        DCC 5/22     ???       1.2.6.B   Deleted - component-based .... simulation tools. Added - This is not necessary. Independence NP       2&3
                                         criteria needs to be maintained only to submit component level data. Manufacturers or any
                                         other trained entity should be allowed perform whole product assembly based on approved
  171                                    components
  172 MKW 5/22       Neg       1.2.6.B   IA is not part of the component approval procedure.                                              NP   2 - See #C 147
      TDC 5/22       Neg       1.2.8     Liability disclaimer                                                                             p    4
  173                                    • Editorial change
  174 DCC 5/22       ???       1.2.2.E   Added - certified simulations and testing services and reports                                   NP   2
  175 DCC 5/22       ???       1.2.1.F   Added - labels and                                                                               NP   2
      DCC 5/22       ???       1.2.1.G   Added - Maintains an online real-time listing of component performance (i.e., U-factor, SHGC,    NP   2
  176                                    VT) for frame systems, glass and glazing layers, and spacers.
  177 DCC 5/22       ???       1.2.1.H   Added - conducts round robins, and inspects laboratories, IAs                                    NP   2
        DCC 5/22     ???       2.1.2                                                                                                           2
  178                                    deleted section - This is already spelled out in 302 document and should not be repeated here    NP
        DCC 5/22     ???       2.1.3     Revised to read - Approved glazing shall be uploaded by LBNL into the Glazing Component          NP   2
  179                                    Library and the # sign added in the library to signify approved status.
  180 DCC 4/20       N/A       2.1.B     This is already spelled out in 302 document and should not be repeated here.                     NP   2 - same as #C178
      DCC 5/22       ???       2.2.1     Revised to read - A. The manufacturer of the spacer shall submit drawings and bill of materials NP    1&2
                                         to the certified simulator for preparing THERM drawing of the spacer according to the
                                         requirements of NFRC 104 [DCC: It makes no sense to assign number 302 to spacer
                                         document, since 300 series deals with solar-optical properties of transparent materials.A. The
                                         manufacturer of the spacer shall submit drawings and bill of materials to the certified simulator
                                         for preparing THERM drawing of the spacer according to the requirements of NFRC 104 [DCC:
                                         It makes no sense to assign number 302 to spacer document, since 300 series deals with solar-
                                         optical properties of transparent materials.

  181
        DCC 5/22     ???       2.2.1     Added - B. The manufacturer of the spacer shall submit one physical sample, at least 1 ft. long. NP   2
  182
        DCC 5/22     ???       2.2.1     Added - E After the IA has approved spacer, it is automatically assigned # sign indicating       NP   2
  183                                    approved status..




NFRC CMA-PCP
Informational Draft Comments                                                64591064-c170-4c11-a8e0-572654ca4c69.xls                                               Page 11
        MKW 5/22     Neg       2.2.1      Spacer peer review rules have not been developed. Cannot approve a document that has           NP     1 - Technical committee (Tech. C)
                                          procedures that still need to be developed.
                                          Spacer grouping rules have not been developed. Cannot approve a document that has
  184                                     procedures that still need to be developed.
  185 DCC 5/22       ???       2.2.1.1    Deleted                                                                                        NP     2
      DCC 5/22       ???       2.2.1.B    Revised to read - Certified simulator shall upload THERM model of the spacer to the spacer       NP   2
                                          component library and NRFEN shall notify IA that the spacer is pending approval.D. Spacers
                                          can be subject of grouping rules, as detailed in NFRC 104. Each spacer shall be assigned
                                          grouping category (automatically, based on the effective conductivity of the spacer assembly),
                                          which will allow manufacturer to later select either actual spacer performance or grouped spacer
  186                                     performance.

  187 DCC 5/22       ???       2.2.2      Deleted                                                                                        NP     2
  188 DCC 5/22       ???       2.2.3      Deleted                                                                                        NP     2
        CGC 5/31     Neg       2.2.4      (COMMENT: See earlier comments regarding the development of the spacer grouping rules.)        NP     1 - Technical committee (Tech. C)
  189
  190 DCC 5/22       ???       2.2.4      Deleted                                                                                        NP     2
      DCC 4/20       N/A       2.2.A      It makes no sense to assign number 302 to spacer document, since 300 series deals with solar- NP
  191                                     optical properties of transparent materials.                                                          2
      JS 4/20        N/A       2.3.2.C    Multiple framing systems may be subject to frame grouping rules where the grouped products NP
                                          shall use the performance values of the simulated frame group leader.
                                          [Placeholder for future frame grouping rules. Alternately, refer to a new technical document,
  192                                     NFRC 304, which contains this information.]                                                           1 - Technical committee (Tech. C)
  193 CGC 5/31       Neg       2.3.B      (COMMENT: See earlier comments regarding the development of the frame grouping.)               NP     1 - Technical committee (Tech. C)
      MKW 5/22       Neg       2.3.B      Frame grouping rules to be developed. Once again, we should not be approving the PCP until NP         1 - Technical committee (Tech. C)
  194                                     all procedures have been developed and approved.
      CGC 5/31       Neg       2.3.C      (QUESTION: Why are "NFRC Expert Reviewers" needed if the work has been done by a              NP      2
  195                                     simulator?)
      DCC 5/22       ???       2.3.C      Revised to read - The NFRC accredited simulation laboratory shall upload the framing system NP        2
                                          model into the framing component library, and NRFEN shall notify IA of the pending review and
  196                                     approval
  197 MKW 5/22       Neg       2.3.D      Expert Reviewers - this term needs to be defined.                                              NP     2 - see # C 48
  198 MKW 4/6        N/A       3.1.1.C    {LAP} This is an ongoing inconsistency within this document.                                   NP     2
        MKW 4/6      N/A       3.1.2.A    These entities are not accredited. They are approved. There should be a new provision within NP
  199                                     the LAP to accommodate the Approved Calculation Entity.                                               1 - LAP
  200 DCC 5/22       ???       3.1.A      Added - thermal and solar-optical                                                            NP       2
      DCC 5/22       ???       3.1.B      Revised to read -                                                                              NP     2
                                          iv. Identification of Framing System manufacturer and model #
                                          v. Fenestration product operator
                                          vi. Layout of framing system model #s for the fenestration product
  201                                     vii. Identification of the permit issuance agency and contact information
  202 CGC 5/31       Neg       3.1.B.i    Deleted - but not limited to                                                                   NP     2
      DCC 5/22       ???       3.1.B.ii   Revised to read -                                                                              NP     2
                                          a. number of lites
                                          b. glass manufacturer and model #
                                             c. gas-fill (if applicable)
                                          e. coated surface placement
                                          g. gap between lites
                                          h. glazing bite
  203




NFRC CMA-PCP
Informational Draft Comments                                                64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                Page 12
        TK 5/22      Neg       3.1.B.ii    deleted - shall be certified by nationally recognized certification agency which is recognized by   NP    2 & 3 - Recognition to be discussed by the BOD
  204                                      NFRC.
        CGC 5/31     Neg       3.1.B.iii   (QUESTION: Does NFRC maintain criteria under which a certification program can become               NP    1 & 2 depends on 204 above
  205                                      "recognized"?)
        DCC 5/22     ???       3.1.B.iii   Revised to read -                                                                                   NP    2 - This is a good sugesstion more clear.
                                           a. Spacer manufacturer and model #
                                           b. Secondary sealant details
                                           c. Primary sealant details
  206                                      d. Spacer position wrt. the glazing edge
        CGC 4/12     N/A       3.1.C       "system documentation" and "paper-trail files" need to be discussed further to determine          NP
  207                                      specifically what needs to be submitted.                                                                  1 - CAP
        CGC 5/22     Neg       3.1.C       Paragraph C reads: "… The IA will maintain all Documentration files associated with the           NP      1 - CAP
                                           fenestration system, as well as the full project files …". Above comments regarding the
                                           documentation files apply here, however, we believe the reference to "full project files" must be
  208                                      further defined.
  209 DCC 4/20       N/A       3.1.C       Why do we need paper-trail in the age of electronic filing?                                         NP    2
      DCC 4/20       N/A       3.1.C       This is very confusing! How can IA approve label certificate if it is going to receive files 10 days NP   2 - see # C 217
                                           after the certificate has been issued? Let me expose how I see this process working; There are
                                           two potential scenarios, 1) new product line (PL) certification (equivalent to the present-day
                                           certification/re-certification, and 2) new product within the existing product line (equivalent to
                                           present-day addendums). In the first case, Manufacturer/Specifying authority sends
                                           documentation (hard copy or electronically) to the IA, IA creates entry in the NRFEN for the new
                                           PL, certified simulator uploads simulation data in NRFEN, test lab uploads test data in the
                                           NRFEN (all associated with the entry for the PL that IA created earlier), NRFEN performs
                                           logical error check and if everything is OK, issues direction to IA that PL needs approval (there
                                           is a firm deadline associated with this, so that IA can not unnecessarily hold certification, IA
                                           reviews everything for all inconsistencies and errors, confirms documentation with the uploads
                                           and approves PL. PL is given equivalent of # sign and after that ACE can issue label
                                           certificates involving this PL.
                                           In the second scenario, ACE simply applies different glazing and spacer options to
                                           the approved PL. No further interaction with IA is required. Certificates are issued
                                           on the spot to the ACE and forwarded to the Specifying Authority. In case of errors
                                           or non-validation, NRFEN and/or IA issues notification to the ACE and Specifying
                                           Authority about problems and informs about correction action required. If the
                                           corrective actions are not done within the prescribed amount of time, certification
                                           fee is forfeited and new certification has to be initiated.



  210
  211 DCC 4/20       N/A       3.1.C       Where is it specified how is payment for the label certificate to NFRC handled?                     NP    3




NFRC CMA-PCP
Informational Draft Comments                                                 64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                 Page 13
        DCC 5/22     ???       3.1.C     Revised to read - The Specifying Authority shall select an NFRC Licensed IA prior to the Label NP       2
                                         Certificate issuance. The Specifying Authority shall submit all system documentation either as
                                         a hard copy or electronically, identified in the PCP (“paper-trail” files [DCC: Why do we need
                                         paper-trail in the age of electronic filing?]) to the selected IA within ten (10) days of issuing the
                                         Label Certificate [DCC: This is very confusing! How can IA approve label certificate if it is going
                                         to receive files 10 days after the certificate has been issued? Let me expose how I see this
                                         process working; There are two potential scenarios, 1) new product line (PL) certification
                                         (equivalent to the present-day certification/re-certification, and 2) new product within the
                                         existing product line (equivalent to present-day addendums). In the first case,
                                         Manufacturer/Specifying authority sends documentation (hard copy or electronically) to the IA,
                                         IA creates entry in the NRFEN for the new PL, certified simulator uploads simulation data in
                                         NRFEN, test lab uploads test data in the NRFEN (all associated with the entry for the PL that IA
                                         created earlier), NRFEN
                                          performs logical error check and if everything is OK, issues direction to IA that PL needs
                                         approval (there is a firm deadline associated with this, so that IA can not unnecessarily hold
                                          certification, IA reviews everything for all inconsistencies and errors, confirms documentation
                                          with the uploads and approves PL. PL is given equivalent of # sign and after that ACE can
                                          issue label certificates involving this PL. In the second scenario, ACE simply applies different
                                         glazing and spacer options to the approved PL. No further interaction with IA is required.
                                         Certificates are issued on the spot to the ACE and forwarded to the Specifying Authority.
                                         In case of errors or non-validation, NRFEN and/or IA issues notification to the ACE and
                                         Specifying Authority about problems and informs about correction action required. If the
                                         corrective actions are not done within the prescribed amount of time, certification fee is
                                         forfeited
                                         and new certification has to be initiated]. The IA will maintain all files associated with the
                                         fenestration system, as well as the full project files, for verification purposes for a period of two
                                         (2) years. Electronic copy becomes permanent record on an NFRC server. [DCC: Where is it
                                          specified how is payment for the label certificate to NFRC handled?]

  212
  213 MF 5/22        Neg       3.1.C     Issue a PRELIMINARY label Certificate.                                                           NP     2
      MKW 5/22       Neg       3.1.C     We need to determine what the documentation trail files are. No sense burying the Ias in         NP     1 - CAP
  214                                    paper.
  215 DCC 4/20       N/A       3.1.D     See above.                                                                                       NP     2
        DCC 5/22     ???       3.1.D     Revised to read - Label Certificate is issued for approved Product lines [DCC: see above] by     NP     2
                                         the NRFEN to ACE, which is then forwarded to the Specifying Authority, unless Specifying
  216                                    Authority is ACE itself, in which case forwarding is skipped.
  217 MF 5/22        Neg       3.1.D     Issue a FINAL label Certificate.                                                                 NP     2
  218 MKW 5/22       Neg       3.1.D     CAP sections to be written - see general comments.                                               NP     1
  219 MF 5/22        Neg       3.1.E     No comment was included with response.                                                           NP     Non-germane, no comment submitted
      DCC 4/20       N/A       3.3.1.C   I have small corporation business for 11 years, but I never obtained any “business license”.     NP
                                         What business license are we talking about? DUNS number? State Department of Labor
  220                                    code, Federal ID number? What? Please be specific.                                                      2 - actual section ref 3.3.1.c




NFRC CMA-PCP
Informational Draft Comments                                                64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                 Page 14
        DCC 5/22     ???       3.2.2     Revised to read - A. Training shall be available to anyone seeking certification as an ACE and NP     2
                                         is employed by an organization. Specific requirements for training and qualifications are set
                                         forth in the LAP [DCC: I would like to offer some ideas for LAP: ACE shall complete a 4 hour,
                                         NFRC-sanctioned training either on the use of NRFEN, which can be taken either in person at
                                         the scheduled location or on line, which includes online testing.] ACE shall pass NFRC supplied
                                         exam. For additional details see LAP.
                                          [DCC: I think that this should not be in PCP. This is LAP language]
                                         B. Upon the completion of the NRFEN training and passing exam, ACE shall sign a license
                                         agreement with the NFRC, after which ACE shall be qualified to generate bid and certification
                                         level reports.

  221
        DCC 4/20     N/A       3.2.2.A   I would like to offer some ideas for LAP: ACE shall complete a 4 hour, NFRC-sanctioned           NP
                                         training either on the use of NRFEN, which can be taken either in person at the scheduled
  222                                    location or on line, which includes online testing.                                                   Non-germane
  223 DCC 4/20       N/A       3.2.A     I think that this should not be in PCP. This is LAP language.                                    NP   2
  224 DCC 5/22       ???       3.2.A     Deleted                                                                                          NP   2
        CGC 5/31     Neg       3.2.A     QUESTION: What is the criteria to obtain the license?) (COMMENT: See earlier comments       NP        2
  225                                    regarding the use of the software tool.)
        DCC 5/22     ???       3.2.A     Revised to read - A NFRC license is attainable to an Approved Calculation Entity, ACE, who  NP        2
                                         desires to calculate the performance rating values of component-based whole product systems
                                         in accordance with NFRC 100 using NRFEN [DCC: ACE only needs to know how to use
                                         NRFEN, not other NFRC-approved software tools, like THERM or WINDOW]. Deleated B & C
  226
        CGC 5/31     Neg       3.2.B     (QUESTION: What is the criteria for "qualifying"?) (COMMENT: See earlier comments                NP   1 - LAP
  227                                    regarding the use of the software tool.)
        CGC 5/22     Neg       3.2.C     There needs to be another category -- Possibly Design Calculation Entity that would allow        NP   2
                                         anyone interested in using the calculation software tool for design & development to gain
  228                                    access and use.
  229 MT 5/22        Neg       3.2.C     This section would limit the market's ability to obtain pre-bid performance numbers.             NP   2
      DCC 5/22       ???       3.3.1.A   Revised to read - A. Qualification requirements for the approval of ACE shall require that the   NP   2
                                         agency employ at least one full-time NFRC ACE on staff. The ACE shall be responsible for all
  230                                    NFRC reports issued
        DCC 5/22     ???       3.3.1.B   Revised to read - Upon signing an NFRC license agreement, the ACE shall be registered to         NP   2
                                         utilize the NRFEN and shall be issued a licensee number. The licensee number authorizes the
                                         ACE to generate the NFRC-sanctioned reports for the Specifying Authority.
  231




NFRC CMA-PCP
Informational Draft Comments                                               64591064-c170-4c11-a8e0-572654ca4c69.xls                                          Page 15
        DCC 5/22     ???       3.3.1.C       Revised to read - ACE shall be employed by a business organization, further referred to as          NP        2
                                             “organization” that maintains a business license recognized by the State or Province in which
                                             its staff are employed [DCC: I have small corporation business for 11 years, but I never
                                             obtained any “business license”. What business license are we talking about? DUNS number?
                                             State Department of Labor code, Federal ID number? What? Please be specific]. The NFRC
                                             licensee number shall be tied to both the individual staff and organization, where organization
                                             shall hold organizational license, while individual shall hold individual license, in the form of a
                                             sub-license to the organziation (e.g., Organization may hold License # CAR-000, while
                                             individuals would hold license numbers CAR-001, CAR-002, and so forth). In the event that the
                                             individual originally obtaining the NFRC licensee number is no longer employed by the
                                             organization, the organization shall provide replacement individual, subject to the completion of
                                             the course and passing of the exam, and shall assign the same license number to the
                                             replacement individual.
                                             If the replacement individual has not been provided in the allotted time frame, the license that
                                              individual number shall be deactivated. If the organization is left without any ACE and has not
                                             provided any replacement in the allotted time period, or if the organization is no longer a legal
                                             entity, the organizational license shall expire. Organization and at least one ACE shall
                                             re-register with the NFRC for a new licensee in order to continue to perform ACE-related
                                             activities and issue NFRC-sanctioned reports. It shall be the responsibility of the organization
                                             to
                                              advise NFRC of any or all business changes that would cause a licensee to re-register or to be
                                              de-listed. (For Additional information, see the LAP)
  232
  233 MKW 5/22       Neg       3.3.1.C       LAP sections to be written - see general comments.                                                       NP   1 - LAP
  234 CGC 5/31       Neg       3.3.2.A       (COMMENT: See earlier comments regarding the use of the software tool)                                   NP   2&3
  235 MKW 5/22       Neg       3.3.2.A       LAP training and qualification sections to be written - see general comments.                            NP   1 - LAP
      TDC 5/22       Neg       4.1.A         Product Certification - Specifying Authority participation                                               NP   2&3
                                             • Removed need to contract IA at start. IA only necessary if randomly selected for audit.
  236
  237 GLC 2/23       N/A       4.1.A.D       Or select another component or component supplier                                                        NP   2
  238 GLC 2/23       N/A       4.1.E         60 days is pretty long, maybe 45                                                                         p    2
  239 GLC 2/23       N/A       4.1.A.F       This procedure needs to be discussed…what do we require in the current program?                          p    4 Already done
  240 GLC 2/23       N/A       4.1.A.G       Where are these rules?                                                                                   NP   Withdrawn
        GLC 2/23     N/A       4.1.B         Question: Don’t we want the Calculation Agency to perform the calculations, not the Specifying           NP
  241                                        Authority?                                                                                                    Withdrawn
  242 MF 5/22        Neg       4.1.B         Too many new "participants".                                                                             NP   2
      TDC 5/22       Neg       4.1.B         Product Certification – Issuance of label certicates                                                     NP   2
  243                                        • Changed language to reflect that label certificate can be issued by sim lab or ACE.
      DCC 5/22       ???       4.1.B.1       Revised to read - 1. Label Certificates can be issued from the NRFEN to the Specifying                   NP   2
  244                                        Authority by ACE utilizing the process specified in Section 2..
  245 MKW 5/22       Neg       4.1.B.1       If this is the process then what does the IA add to the process.                                         NP   2
        DCC 5/22     ???       4.1.B.2       Revised to read - NRFEN allows the ACE, to access component database online, calculate the NP                 2
                                             thermal and solar-optical performance ratings for the whole product, and generate a label
  246                                        certificate or bid-level report.
        DCC 4/20     N/A       4.1.B.2.iii   It was not clear here if signing is required prior to ANY label certificate issuance. If it is, then I   NP
                                             am strongly against it as an unnecessary burden to everybody. License agreement should be
                                             signed once and maintained unless there is a breach of agreement. I have provided specific
  247                                        language addressing that.                                                                                     2




NFRC CMA-PCP
Informational Draft Comments                                                     64591064-c170-4c11-a8e0-572654ca4c69.xls                                                   Page 16
        DCC 5/22     ???       4.1.B.2.iii   Revised to read - iii. The ACE shall be contracted to generate bid-level reports or label              NP   2
                                             certificates using NRFEN.
                                             iii. The Specifying Authority may either print out the label certificate from the NRFEN directly or
                                             may authorize ACE to do so. In either case, the Specifying Authority shall sign and execute the
                                             license agreement with NFRC before issuance of any label and/or project certificates. The
                                             license shall be maintained with NFRC subject to the periodic review by NFRC, but it shall not
                                             be necessary to re-sign license agreement prior to follow-up label certificate issuences. [DCC: It
                                             was not clear here if signing is required prior to ANY label certificate issuance. If it is, then I am
                                             strongly against it as an unnecessary burden to everybody. License agreement should be
                                             signed once and maintained unless there is a breach of agreement. I have provided specific
                                             language addressing that]

  248
        CGC 5/22     Neg       4.1.C         Paragraph C reads "The IA shall seek approval of NFRC prior to converting the Documentation p               4- Add 'hard copy or electronically for storage'
                                             trail document to electronic storage." We believe the most efficient means of the Document
                                             trail submittal and retention will be electronically. We strongly recommend that electronic
  249                                        submittal and storage be allowed.
        CGC 5/31     Neg       4.1.C         (COMMENT: See the earlier comments regarding the need to define the documentation trail              NP     1 - CAP or PCP
  250                                        and consideration of the frequency of the audits.)
        CGC 5/31     Neg       4.1.C         Deleted - The IA shall seek approval of NFRC prior to converting the Documentation trail             p      4 - See # C 249
  251                                        documentation to electronic storage.
  252 DCC 4/20       N/A       4.1.C         NOT!! This is bureaucratic and unnecessary.                                                          NP     2
      DCC 4/20       N/A       4.1.C         To heck with the paper documentation! Who needs piles of paper at this day and age!?                 NP     See 249. Line 253
  253
      DCC 5/22       ???       4.1.C         Revised to read - The [DCC: NOT!! This is bureaucratic and unnecessary] documentation                NP     2
                                             about the products contained in a label certificate shall be documented (i.e., bill of sales,
                                             purchase orders, specifications, etc.) and maintained by Specifying Authority, with the most
                                             important details maintained in NRFEN.. IA shall conduct random audits of these systems to
                                             ensure that the system is accurately reflected in the label certificate issued, and complies with
                                             the requirements of the PCP. [DCC: To heck with the paper documentation! Who needs piles
                                             of paper at this day and age!?]
  254
        GLC 2/23     N/A       4.1.C         We need to be specific regarding what documentation is required and what is optional.                NP
  255                                                                                                                                                    Withdrawn
  256 MF 5/22        Neg       4.1.C         Last sentence - currently everything can be electronic.                                              p      4 - See # C 249
      MKW 5/22       Neg       4.1.C         Need to set documentation requirements. The way this is written I'm glad I'm not an IA.              NP
  257                                                                                                                                                    1 - CAP or PCP
      TDC 5/22       Neg       4.1.C         Product Certification – IA Audits                                                                    NP     1 - CAP
                                             • IA only audits a randomly selected fraction of product certificates, so language changed to
                                             reflect that. Suggested NFRC choose the fraction, but not to be higher than 10%.
  258
        CGC 5/31     Neg       4.1.D         (QUESTION: Why would there be a situation where a system could not be certified using the            NP     2&3
  259                                        simulation and calculation tools?)
  260 DCC 4/20       N/A       4.1.D         {Comment on Testing} I agree.                                                                        NP     2
      DCC 5/22       ???       4.1.D         Revised to read - Physical testing shall be performed on a very limited basis and no more than       NP     2
                                             for 1% of the systems considered. The IA shall inform Specifying Authority when physical
  261                                        testing needs to be performed
  262 GLC 2/23       N/A       4.1.D         Question: Should this be Specifying Authority?                                                       NP     2
      MKW 4/6        N/A       4.1.D         {Comment on Testing} Discussion has been had. See previous comments on this item.                    NP
  263                                        Testing may occur on challenged submissions.                                                                2
      MKW 5/22       Neg       4.1.D         Physical Testing indicates that's only products which cannot be simulated will be tested.            NP     2
  264                                        Therefore the two clauses are inconsistent with each other.



NFRC CMA-PCP
Informational Draft Comments                                                    64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                    Page 17
  265 MF 5/22        Neg       4.1.D&E          Test only non-simable products but non validation says to sim.                                     NP   2- NFRC nonconformance requirements are not defined.
  266 CGC 5/31       Neg       4.1.E            Deleted entire section on non-validation.                                                          NP   2
        GLC 2/23     N/A       4.1.E            I don’t thinkl we want the Specifying Authority to be the one to “elect” whether to the calcs…it   NP
  267                                           should be the IA or NFRC …someone independent                                                           2
        MKW 5/22     Neg       4.1.E            This clause assumes that products will be tested whereas testing requirements have not been        NP   2
                                                determined for the CMA program. A the October 5, 2005 meeting in Atlanta, the task group
                                                agreed that testing would not be required as it would drive up the cost of certification.
  268
        TDC 5/22     Neg       4.1.E            Product Certification – Non-validation                                                             NP   2
                                                • If no testing is required except when a product cannot be simulated, then the section on non-
                                                validation is not relevant. (But I do realize the testing issue is not yet resolved.)
  269
  270 DCC 4/20       N/A       4.1.E.G          This comment is just repeated here.                                                                NP   2
      DCC 5/22       ???       4.1.E.i          Revised to read - A. The IA shall notify in writing the Specifying Authority, ACE, Simulation and NP    2
                                                the Testing Laboratory of the non-validation. These parties shall attempt to establish reasons
  271                                           for the non-validation.
        DCC 5/22     ???                        Revised to read - B. These parties shall have ten no more than 30 calendar days to identify the NP      2
  272                          4.1.E.ii         reason(s) for the non-validation.
  273 DCC 5/22       ???       4.1.E.iii        Added - at the expense of the component manufacturer                                            NP      2
      MT 5/22        Neg       4.1.E.iii - iv   The SA will not agree to bear the burden of these costs. Also … who is responsible if the          NP   2
                                                softare yields wrong ratings? The owner/architect will be looking for fault.
  274                                           (Comment: Discussion needs to be ….) - Physical testing is not required at this point.
        MKW 5/22     Neg       4.1.E.vi         Which committee is responsible for the decision determining the values for certification?          NP   2 - Recommendation the technical committee. See # 265
  275
        GLC 2/23     N/A       4.1.F            We need to define recertification requirements to individual products rated and certified using NP
                                                the component based ratings …and what if a manuf or specifying authority wants to recertify a
                                                system that was used previously…it isn’t an everyday issue, but “old” extrusions sometimes get          2 -Good commoent, need to be considered. Comment is that one
  276                                           reused.                                                                                                 can always do cerification again.
  277 MF 5/22        Neg       4.1.F            What about recertification of the buckets?                                                         NP   2
  278 DCC 5/22       ???       4.1.G            Changed "approved by" to "subject to"                                                              NP   2
        DCC 4/20     N/A       4.1.H            All of frame grouping rules should be spelled out in one place, not like this one at a time.       NP
  279                                                                                                                                                   2
  280 DCC 5/22       ???       4.1.H            Revised to read - at the expense of the component manufacturer                                     NP   2
      DCC 5/22       ???       4.2.B            Revised to read - Product performance shall be calculated using NFRC-approved software tool NP          2
  281                                           NRFEN and from approved components as specified in Section 2.
  282 DCC 5/22       ???       4.2.B            Rest of section deleted                                                                        NP       2
        TDC 5/22     Neg       4.3.B            Project Certification                                                                          NP       2
                                                • Included language that allows area-weighted averages for U and SHGC to be reported for the
                                                whole project. This info is often useful for U and SHGC, but not pertinent for VT. This should
  283                                           be allowed, although not mandatory.
        GLC 2/23     N/A       4.3.C            We need to specify the required information and who is responsible for providing it…not just       NP
  284                                           say “information about the project”.                                                                    1 & 2 - Label T.G.
        DCC 5/22     ???       4.3.D                                                                                                                    2 - Appendix A is not there. Do we want to include Appendix A or
  285                                           Deleted                                                                                            NP   say to be development
  286 MKW 5/22       Neg       4.3.D            See Appendiz A - project certificate has not been approved, where is Appendix A?                   NP   1 & 2 - See # C 285
  287 DCC 5/22       ???       4.3.E            Added - Project Certificate shall comply with the format detailed in Appendix A.                   NP   1&2




NFRC CMA-PCP
Informational Draft Comments                                                       64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                  Page 18
        GLC 2/23     N/A       5.1.A       (Comment: This appears to require the paper review/audit of every project. Discussion during        NP
                                           previous task group meetings cautioned that 100 percent audit of the paper-trail will result in a
                                           massive accumulation of documents that will quickly become unmanageable for the IA’s.
                                           Contractual requirements of the commercial construction process serve as assurance for the
                                           parties involved. A random paper-trail audit of 10 percent of the non-residential would be
  288                                      reasonable.)                                                                                             2&3
  289 MT 5/22        Neg       5.1.B       It is not appropriate for the Ias to notify the "code official (permit granting agency)".           NP   2
      TDC 5/22       Neg       6.1.3       NFRC Administrative Action                                                                          p    4
  290                                      • Corrected wrong section reference.
  291 MKW 4/6        N/A       6.5.1.F     What is the basis for the non-refundable payment of $1,000.                                         NP   3
        MKW 4/6      N/A       6           This whole section is over written and unnecessarily bureaucratic. It does not need to be this      NP
  292                                      complicated in order to have meaning.                                                                    2
        TDC 5/22     Neg       6.3         Parties to Appeal process                                                                           NP   2
                                           • Clarified language about IA’s involvement (IA did not issue certification, only involved with the
  293                                      original challenge.)
        TDC 5/22     Neg       6.6.3.1     Submissions by parties                                                                              NP   2
  294                                      • There appears to be redundant information which needs to be cleaned up.
        TDC 5/22     Neg       6.6.3.2     Submissions by parties                                                                              NP   2
  295                                      • There appears to be redundant information which needs to be cleaned up.
        TDC 5/22     Neg       6.6.3.3     Submissions by parties                                                                              NP   2
  296                                      • There appears to be redundant information which needs to be cleaned up.
        TDC 5/22     Neg       6.6.3.4     Submissions by parties                                                                              NP   2
  297                                      • There appears to be redundant information which needs to be cleaned up.
        TDC 5/22     Neg       6.6.3.5     Submissions by parties                                                                              NP   2
  298                                      • There appears to be redundant information which needs to be cleaned up.
  299 MKW 4/6        N/A       6.6.3.5.D   The ACE does not issue the label certification so don’t see the need for this condition.            NP   2 - Confilcts with IA role or obligation
      TDC 5/22       Neg       6.6.3.6     Submissions by parties                                                                              NP   2
  300                                      • There appears to be redundant information which needs to be cleaned up.
      TDC 5/22       Neg       6.6.3.7     Submissions by parties                                                                              NP   2
  301                                      • There appears to be redundant information which needs to be cleaned up.
      MKW 4/6        N/A       6.6.6       I would support a permanent Appeals Committee. This committee should have balanced                  NP
  302                                      representation.                                                                                          2&3
  303 MKW 4/6        N/A       6.6.6       I would like more discussion on the designation of the appointees.                                  NP   2&3
        MKW 5/22     Neg       6.6.6       I would like more discussion on the designation of the appointees. This should include              NP   2
  304                                      balanced representation.
        CGC 5/22     Neg       Foreward    The draft document Forward references several situations that have not been fully determined        NP   2
                                           and/or defined at this time. The document Forward should be deleted until such time as the
  305                                      program is fully defined.
        JS 5/22      ???       Foreward    1st paragraph - …. ultra-violet (UV) performance, and comfort performance. {{Comment was            NP   2
                                           received that the last sentence should be deleted because the document should not speculate
  306                                      on future developments.}}




NFRC CMA-PCP
Informational Draft Comments                                                   64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                        Page 19
        JS 5/22      ???       Foreward   2nd paragraph- …. by an NFRC Independent Certification and Inspection Agency (“IA”). The          NP     2
                                          requirements of the rating, certification, and labeling program (the "Certification Program") are
                                          set forth in the most recent version of the NFRC Product Certification Program (the “PCP”), as
                                          amended, updated or interpreted from time to time. Through the Certification Program and its
                                          companion laboratory accreditation program (the "Accreditation Program") , set forth in the
                                          NFRC Laboratory Accreditation Program (the “LAP”), as amended, updated or interpreted from
                                          time to time, and IA licensing program (the "IA Program"), set forth in the most recent version
                                          of the NFRC Certification Agency Program (the “CAP”), as amended, updated or interpreted
                                          from time to time, NFRC intends to ensure the integrity and uniformity of NFRC ratings,
                                          certification and labeling by ensuring that specifying authorities, testing and simulation
                                          laboratories, and IAs adhere to strict NFRC requirements.

  307
        JS 5/22      ???       Foreward   3rd paragraph - …. manufacturer/component manufacturer/specifying authority shall rate a            NP   2
                                          product to be certified for mandatory NFRC rating procedures. At present, a
                                          manufacturer/component manufacturer/specifying authority may elect to rate products for U-
                                          factor, solar heat gain coefficient, visible transmittance, air leakage, condensation resistance,
                                          or any other procedure adopted by NFRC, and to include those ratings on the NFRC label
                                          affixed to its products (or the NFRC Label Certificate for component based products) . U-factor,
                                          SHGC and VT, AL, and CR rating reports shall be obtained from a laboratory, which has been
                                          accredited by NFRC in accordance with the requirements of the LAP. The rating shall then be
                                          reviewed by an Independent Certification and Inspection Agency (IA) and/or peer view
                                          committee which has been licensed/approved by NFRC. NFRC-licensed IAs also review label
                                          certificate format and content, conduct in-plant inspections and/or paper trail reviews for quality
                                          assurance in accordance with the requirements of the CAP, and issue a product Certification
                                          Authorization Report (CAR) , or an NFRC Label Certificate for component based products and
                                           attachment

  308
        JS 5/22      ???       Foreward   4th paragraph - …. Certified Products Directory (the “CPD”), listing product lines and individual NP     2
                                          products selected by the specifying authority for which product




  309
        MKW 5/22     Neg       Foreward   3rd paragraph-midway: "Accredited Calculation Entity", should be changed to read "Approved        NP     3
                                          Calculation Entity".
  310                                     This has been an on-going issue in the development of the PCP and is not consistant with the
                                          discussions of the task goup (see Atlanta meeting notes). The rational for haveing an
        MT 5/22      Neg       Foreward   "air leakage" should be removed from this component based certification program. To my            NP     2
                                          knowledge, there is not a software tool to certify this performance. This program should be
  311                                     limited to what can only be computer simulated.
  312 MT 5/22        Neg       Foreward   "accredited calculation entity" should read approved calculation entity.                          p      4
      MT 5/22        Neg       Foreward   "NFRC-licensed" IAs also review label certificate format and content - certificate should be a set NP    2
  313                                     format. So, there should be no need to review.



NFRC CMA-PCP
Informational Draft Comments                                                64591064-c170-4c11-a8e0-572654ca4c69.xls                                   Page 20
        TDC 5/22     Neg       Foreward   Editorial changes.                                                                                  NP   2&3
                                          IA not necessary to review whole-product rating calculation, issue CAR, or issue label
                                          certificate. These can be done directly by ACE.
  314                                     IA does not audit every product rating, only a prescribed fraction.
        TK 5/22      Neg       Foreward   The forward describes a process in which numerous issues have yet to be decided. As a result NP          2
                                          I think it would be prudent to write the forward in accordance with the final agreed upon draft.
  315
        MKW 4/6      N/A       Foreword   Perhaps we should differentiate between plant fabricated and site-built ie. Store fronts tend to    NP   2
                                          be plant fabricated (much like residential products) while curtainwalls are field glazed or site-
  316                                     built.
        CGC 5/22     Neg       General    During task group and subcommittee meetings, discussion has been held concerning the             NP      2
                                          requirement for an area-weighted U-Factor and Solar Heat Gain Coefficient (SHGC) for a
                                          project. We believe this should be allowed as a part of the program but not a requirement on all
  317                                     projects.
        CGC 5/22     Neg       General    On numerous occaisions, we have asked the NFRC Board of Directors about efforts being               NG   Non-germane - needs separate effort
                                          taken to meet the goal of educating the membership and Board of Directors about the
                                          commercial construction industry. To date, we have not seen effort by the oard of Directors to
                                          reach out to registered design professionals, building owners, developers, building managers,
                                          general contractors or glazing contractor to assess the needs and practices of the commercial
                                          construction industry. We believe acceptance and support of the program will require proper
                                          consideration of the needs of all participants in the commercial construction industry.
  318
        CGC 5/22     Neg       General    It was my understanding that this was a review and comment period only. Not a ballot with  NG            Non-germane
  319                                     voteing.
        DCC 4/20     N/A       General    DCC also made many text changes to the draft which are not presented here because they are NP
  320                                     not comments and are too numerous to be repeated here.                                                   Comment is not current
  321 DCC 4/20       N/A       General    DCC also submitted comments by e-mail on the 4/20 PCP draft as follows;                    NP            Comment is not current
      DCC 4/20       N/A       General    No need to have IA involved at the level of whole product certification, other than random          NP
  322                                     checks of issued label certificates.                                                                     3
        DCC 4/20     N/A       General    Interchanging use of terms "peer review" and "expert review" is confusing to me. I think that it is NP
                                          cleaner to use terms "certified simulator" and "peer review". We have been using terms
                                          "certified simulator" and "accredited lab" for work where certification of the simulator and
                                          accreditation of lab is necessary, for long time, so there is no need to invent new terminology
  323                                     for the same thing. KISS principle.                                                                      2
        DCC 4/20     N/A       General    Peer review should be allowed only for glass entries, in line with the current practice. Again, NP
  324                                     KISS principle.                                                                                          2
        DCC 4/20     N/A       General    Spacers and frame components require identical skills and knowledge for simulation (albeit,     NP
                                          spacers are smaller and less complex), so they should both be done by certified simulators and
  325                                     we should be all spared of peer review of any of that.                                                   2
        DCC 4/20     N/A       General    IAs should BE "directly" involved in all component submittals that require certified             NP
                                          simulators/accredited labs (i.e., spacers and frames) and they should provide approval of these.
  326                                                                                                                                              2
        DCC 4/20     N/A       General    IAs should NOT be involved (other than random checks) in any portion of the process after the       NP
                                          components had been approved (i.e., use of NRFEN, generation of label certificates, etc.).
                                          This is important to keep the process as bureaucratic-free as possible. This is especially
                                          important for bid-level reports. Simplicity of using NRFEN and thorough documentation that is
                                          available through NRFEN archiving system, that provides easy trace-back in case something
                                          needs to be checked, will allow for this simplified route.
  327                                                                                                                                              2




NFRC CMA-PCP
Informational Draft Comments                                                 64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                    Page 21
        DCC 4/20     N/A       General   Allow frame grouping on the component level. This would include definition of default (punitive) NP
  328                                    groups.                                                                                                  1&2&3
        DCC 4/20     N/A       General   Streamlining of mandatory documentation and removal of the requirement to keep paper-trail. p
                                         This is 21st century, let's save the trees and reduce the burden when technology allows for that.
  329                                                                                                                                             4 - See # C 249
        DCC 4/20     N/A       General   Provided for clarity in the process of ACE (relationship between company and individual and        NP
  330                                    their relationship with NFRC).                                                                           2
        DCC 4/20     N/A       General   Provided detailed vision of the flow from component simulation to upload to validation to IA       NP
                                         approval to the role of ACE to the use of NRFEN to the issuance of label certificate and finally
  331                                    to what happens if there are problems in between.                                                        2
        MF 5/22      Neg       General   Initally the glass buckets was done by peer review and the spacer & frame buckets the NFRC      NP       2
                                         certified ratings meaning that simulation and some degree of testing was done. I therefore
                                         thought that further testing would not be required. What are the testing requirements under the
  332                                    current scenario?
        MKW 5/22     Neg       General   It is not possible to approve this document when there are four substantial unresolved issues:     NP    1 - First two issues need to be deveoped by technical committee.
                                         1. Spacer grouping rules                                                                                 PCP only informs the user to follow the procedures. APC and CPC
                                         2. Framing grouping rules                                                                                would write language based on NFRC policy.
                                         3. Development of modified LAP to accommodate the Approved Calculation Entity (ACE)
                                         4. CAP sections to be developed determining conformance for this program.


  333
        MT 5/22      Neg       General   This is back-up to my "Do Not Approve" ballot submitted on the component-based PCP                  NP   2
                                         information draft. I feel that the proposed language in the certification program is not functional
                                         in the commercial construction market. The "Specifying Authority" (SA) is limited by definition,
                                         and other requirements, to be an Architect, Specifier, or Project Engineer. The responsibilities
                                         of this program place undue burdens on the SA. As a quick recap of the proposed program,
                                         the SA authority must:
                                         -contact an ACE to perform calculations (prebid & post construction)
                                         -the SA must supply very detailed information to an ACE in order for this calculation to be made
                                         -verify that IG units supplied to the jobsite are certified by an IG certification program
                                         -enter into a contractural relationship with an IA to review project documentation and audit their
                                         project/paper trails ... all of this in order to obtain an official label certificate
                                         -enter into another agreement with NFRC to use the NFRC certification mark
                                         -must pay any fees associated with a Documentation-trail audit if they are selected

  334
        MT 5/22      Neg       General   In my opinion, this type of responsibility will not be accepted by those defined as "Specifying    NP    2
                                         Authorities". Some recommendations to include in the rewrite are:
                                         -broaden the definition of the SA
                                         -have the SA enter into an agreement with an ACE
                                         -have an ACE enter into an agreement with NFRC and IA. The IA would then audit the ACE's
                                         activities. The licensing fees associated with an ACE could be structured to cover costs of
                                         random audits (possibly 10%)
                                         -have the SA enter into an agreement with NFRC in order to obtain the certificate




  335




NFRC CMA-PCP
Informational Draft Comments                                               64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                                   Page 22
        MT 5/22      Neg       General   In conclusion, I propose that a rewrite be done on this informational draft and that it be re-     NP     2
                                         issued as an informational draft to receive further comments. I can not provide an approval
                                         vote for this program until these major issues are resolved and "to be developed" sections are
  336                                    final.
  337 PM 5/22        Neg       General   Manufacturer needs to be capable of being an ACE.                                                  NP     3
  338 PM 5/22        Neg       General   Frame grouping rules need to be established.                                                       NP     1 - Technical committee (Tech. C)
  339 PM 5/22        Neg       General   Default framing values need to be determined.                                                      NP     1 & 3 for authorization to use defaults
  340 PM 5/22        Neg       General   Spacer grouping rules need to be established.                                                      NP     1 - Technical committee (Tech. C)
  341 PM 5/22        Neg       General   Default spacer values need to be determined.                                                       NP     1 - Technical committee (Tech. C)
  342 PM 5/22        Neg       General   Software tool for calculations need to be developed and approved.                                  NP     1 - Technical committee (Tech. C)
        PM 5/23      Neg       General   The following comments are referenced to the first occaision that they appear in the draft         NP     2
                                         document. Most of the items appear repeatedly and our comments would also apply to related
  343                                    additional sections of the document as they occur.
        TDC 5/22     Neg       General      Comprehensive frame grouping is essential for the new rating program to be practical.            NP    1&2
                                         Considering all the various options available in architectural framing systems, there are literally
                                         hundreds-of-thousands of frame product combinations that potentially have to be included. It is
                                         simply not feasible to simulate every possible combination, and the costs would be staggering.
                                         Both new simulation frame grouping rules and optional default frame categories are essential to
                                         reducing this to a realistic number. New frame grouping rules are needed to reduce the
                                         number of potential product lines when doing simulations. Furthermore, the ability to use
                                         default frame categories with default performance values without simulation is needed to
                                         reduce the number of required simulations, particularly for one-time custom extrusions which
                                         may only be used once.
                                            I also believe the same approach of comprehensive grouping rules and default categories
                                         could be equally applied to spacer submission.

  344
        TDC 5/22     Neg       General   Manufacturers should be allowed to do final whole product certification. Manufacturing               NP   3
                                         companies should also be allowed to be accredited as an Approved Calculation Entity. This
                                         would allow a qualified engineer from the manufacturer to directly perform the final web-based
                                         combined glass+spacer+frame calculation to get a whole product rating, rather than always
                                         being forced to use an accredited simulation lab for such a simple process. Independence can
                                         still be maintained by having final review by an approved Independent Agency (IA), although
                                         this is probably also unnecessary because of the random audit and challenge processes. If the
                                         manufacturer chooses to use an accredited simulation lab to be their ACE and do the final
                                         whole-product calculation, then review by an IA is definitely not required. In either case, at least
                                         one independent body would be reviewing the final rating.

  345
        TDC 5/22     Neg       General   Independent Agency review for whole-product calculations is unnecessary. The IA is                NP      3 - Policy, Guidance from NFRC - BOD
                                         responsible for auditing a fraction of randomly selected whole-product certificates, and may also
                                         be involved with the submission of component data. There is no need for IA’s to be involved
                                         with and review every whole product calculation, which is simply selecting the appropriate glass,
                                         spacer, and frame from a web-based program. This extra bureaucracy adds extra cost without
  346                                    much value.




NFRC CMA-PCP
Informational Draft Comments                                               64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                          Page 23
        TDC 5/22     Neg       General   Only a fraction of whole-product certificates need to be audited with a documentation trail. The NP   3 - Policy, Guidance from NFRC - BOD
                                         cost and burden will be overwhelming if an audit and document trail is required for every
                                         product certificate. The same objective can be achieved with a much smaller fraction (10%) of
                                         randomly selected products. If the concern is “cheating”, normal contracts within the
                                         commercial building industry already are a much stronger force than IA audits for ensuring the
                                         right product is specified and installed. Also, there is still a challenge process if anybody wants
                                         to challenge a company’s claimed rating.
  347
        TDC 5/22     Neg       General   Overall, to be successful, the process needs to be as streamlined as possible to reduce        NP     3 - to be dissused ar BOD
                                         bureaucracy and cost. If we do not, the system will be ignored and problematic for code
                                         officials, manufacturers, and building owners. On the other hand, a streamlined process will
                                         encourage much broader use, which in the end benefits everyone -- NFRC, consumers, code
                                         officials, manufacturers, and building owners.
  348
  349 NK 5/22        Abs       N/A       Thanks                                                                                         NG     Non-germane
  350 TG 5/22        App       N/A       None                                                                                           NG     Non-germane




NFRC CMA-PCP
Informational Draft Comments                                              64591064-c170-4c11-a8e0-572654ca4c69.xls                                                                    Page 24
     Commenter Vote on PCP Informational Draft- By Section




     Commentor Category Section


     CGC 5/22     Neg   1.1




 1
     CGC 5/31     Neg   1.1




 3
32 MKW 5/22       Neg   1.3
   MT 5/22        Neg   1.3

36
44 MKW 4/6        N/A   2.2
   DCC 5/22       ???   4.1
56
59 CGC 5/31       Neg   5.1
62 MKW 5/22       Neg   5.1
76 MKW 4/6        N/A   1.1
     MKW 4/6      N/A   1.1

77
78 CGC 5/31       Neg   1.2.1.D
   MT 5/22        Neg   1.2.1.D

79
     CGC 5/22     Neg   1.2.2

81
82 MKW 4/6        N/A   1.2.2
      TDC 5/22   Neg   1.2.2




84
      CGC 5/22   Neg   1.2.2.D




98
      MKW 5/22   Neg   1.2.3.2.C
116
      CGC 5/22   Neg   1.2.3.3
120
122 MF 5/22      Neg   1.2.3.3
    MKW 5/22     Neg   1.2.3.3
123
    TGR 5/22     Neg   1.2.3.3

124
      GLC 2/23   N/A   1.2.3.3.A



125
      MT 5/22    Neg   1.2.3.4.B



134
      CGC 5/22   Neg   1.2.3.5




140
      MKW 5/22   Neg   1.2.3.5
141
      MT 5/22    Neg   1.2.3.5




142
153 MF 5/22      Neg   1.2.5
    MKW 4/6      N/A   1.2.5

154
      MKW 5/22   Neg   1.2.5



155
      DCC 5/22   ???   2.2.1




181
      MKW 5/22   Neg   2.2.1



184
      CGC 5/31   Neg   2.2.4
189
      JS 4/20    N/A   2.3.2.C



192
193 CGC 5/31     Neg   2.3.B
    MKW 5/22     Neg   2.3.B
194
    MKW 4/6      N/A   3.1.2.A
199
    CGC 5/31     Neg   3.1.B.iii
205
    CGC 4/12     N/A   3.1.C
207
    CGC 5/22     Neg   3.1.C



208
      MKW 5/22   Neg   3.1.C
214
218 MKW 5/22     Neg   3.1.D
    CGC 5/31     Neg   3.2.B
227
233 MKW 5/22     Neg   3.3.1.C
235 MKW 5/22     Neg   3.3.2.A
    CGC 5/31     Neg   4.1.C
250
    MKW 5/22     Neg   4.1.C
257
    TDC 5/22     Neg   4.1.C



258
      GLC 2/23   N/A   4.3.C
284
286 MKW 5/22     Neg   4.3.D
287 DCC 5/22     ???   4.3.E
      DCC 4/20   N/A   General
328
      MKW 5/22   Neg   General




333
338 PM 5/22      Neg   General
339 PM 5/22      Neg   General
340 PM 5/22      Neg   General
341 PM 5/22      Neg   General
342 PM 5/22      Neg   General
    TDC 5/22     Neg   General




344
Vote on PCP Informational Draft- By Section                                                                 *
       CGC = Greg Carney, MKW = Margaret Webb , JS = Joel Smith, DCC = Charlie Curcija,        PM
       = Patrick Muessig, TGR = Tracy Rogers , MF = Marcia Falke, NK =Noel King , TG = Tim                  1
       Gehling, TDC = Tom Culp, MT = Mike Turner, TK = Tony Kamber, GLC = Gary Curtis
                                                                                                            2
                                                                                                            3
                                                                                                            4
                                               Comment                                                     Type


       Third paragraph calls for " … an NFRC approved Calculation Entity ("ACE") for the calculation NP
       of the fenestration system energy indices for which NFRC certification is required …" however,
       the details of what is required for NFRC-Approval" has not been defined. Once the glass,
       spacer and frame databases have been fully developed, we do not believe the use of the
       performance calculation will be a difficult task and therefore, the approval process should be
       minimal in terms of training and cost. Individuals not interested in serving as an "NFRC-
       Approved Calculation Entity" should be allowed to use the software and databases for design
       considerations that may or may not lead to product/project certification. (NOTE: Reference to
       the NFRC_Approved Calculation Entity also appears in numerous other sections of the draft
       and therefore must be furthered defined.)


       Deleted "The Calculation Entity shall be approved by NFRCto use the Component Library". An NP
       NFRC- Calculation Entity shall calculate the values for the fenestration system using NFRC-
       (COMMENT: The "procedures" have not been defined.) procedures and the component library
       database. (COMMENT: The approval process has not been defined. See above comment
       regarding use of the software.)
       Approved Calculation Entity: See comment on section 1.2.5 and general comment.               NP
       Approved Calculation Entity - By requiring an ACE to meet NFRC requirements of the LAP, I    NP
       believe you are limiting the ACE to be an Accredited Laboratory or Simulator. This is not
       acceptable.
       Hard to approve this language when the procedure has not been written                        NP
       Replaced - approved component ratings from a component based library database and            NP
       additional software tools with NRFEN
       (COMMENT: See earlier comments regarding the documentation trail and audits.)                NP
       The documentation trail requirements need to be established.                                 NP
       (what does this mean…”independent NFRC”                                                      NP
       (this is not what the Non residential Task Group agreed to in Atlanta. We agreed to “approved” NP
       so this entity would not be subject to the same rigorous requirements of accredited entities.
       See meeting notes from Atlanta, October 5, 2005)
       (COMMENT: See above comments regarding the approval process);                                NP
       Need to define how NFRC "approves" an "Approved Calculation Entity".                         NP


       Third paragraph notes "… an NFRC-licensed fenestration Specifying Authority …" Question:     NP
       What are the deetails of how someone becomes an NFRC-licensed fenestration Specifying
       Authority?
       Would like to see the hard copy procedure.                                                   NP
Role of Specifying Authority:                                                                    p, NP
• Editorial changes.
• SA does not contract IA to issue label certificate, which can be done by ACE.
• IA only audits a randomly selected fraction of product ratings, so language changed to reflect
that.
• Removed language in section 1.2.2.1 about participating in other certification programs “not
related to energy performance.” Certifying air leakage under AAMA/WDMA/CSA
101/I.S.2/A440 could be considered "energy related" since it is required in IECC and ASHRAE.
This language is not really necessary, anyway.

Provides the first reference to the "… whole product rating specification data retention     NP
(Documentation Trail) …". The requirements of the documentation trail and individual project
requirements have yet to be defined. As we have mentioned in numerous previous meetings,
the contractural nature of the commercial construction industry and well established
documentration requirements of purchase orders, acknowledgements, shipping case tags, etc.,
are an ongoing part of the commercial fenestration industry. The subcommittee needs to
carefully consider the requirements of the documentation trail. We strongly recommend a
minimal audit program where a small percentage of projects require submittal of a limited
number of defined documents. (NOTE: The documentation trail is mentioned in several
sections of the draft and needs to be properly discussed and defined before the product
certification program moves forward for adoption.)


Spacer peer review rules have not been developed. Cannot approve a document that has              NP
procedures that still need to be developed.
The subcommittee needs to develop/finalize the spacer grouping rules before this certification    NP
program moves forward for adoption.
Group Keff for spacers.                                                                           NP
Spacer grouping rules have not been developed. Cannot approve a document that has                 NP
procedures that still need to be developed.
There exists no approved mechanism for grouping spacers at this time. There is an                 NP
assumption that a viable option exists but, for the purposes of having a complete operational
document, this remains an assumption and the section is invalid.
(Comment: There are hundreds of thousands if not millions of possible framing system pieces NP
and/or parts that can be used on commercial window walls, curtain walls, and skylights. It is
not feasible to expect framing system suppliers to be subjected to the cost for modeling of all of
the possible component parts.)
I'm assuming this section applied to Product Line Simulations (see section 4.1.H). I don't  NP
believe "system dimensional tolerances" is appropriate. Maybe "nominal system dimensions".
Also, what is the procedure for adding a section to a product line? (i.e., adding a 4" wide
curtain wall vertical mullion to a standard 2 1/2" curtain wall system.)
The subcommittee needs to develop/finalize the frame grouping rules before this certification     NP
program moves forward for adoption. As we have expressed at numerous meetings, we
strongly believe that the framing system grouping represents a critical element of developing a
product certification program that can be fair, accurate and cost effective. Failure to recognize
the ability to develop framing system grouping and pushing the program forward without this
aspect will dramatically affect the program cost, support, and acceptance by the commercial
fenestration industry.


Frame grouping rules have not been developed. Cannot approve a document that has                    NP
procedures that still need to be developed.
New frame grouping rules need to be developed for the commercial market. It is essential that NP
these rules be developed prior to the approval of this certification program. It is not feasible to
require framing manufacturers to model the thousands of options available within their product
lines. I also believe that default values should be developed. A MFG could choose to use
default values or simulate their own.
Creates ACE.                                                                                      NP
{is responsible for meeting the requirements in the LAP and PCP including, but not limited to,    NP
the following functions:} Thought the intent was that the ACE was NOT subject to the LAP.
(Comment: Need to create requirements for ACE)                                                      NP
This is a substantial issue and will affect the cost-effectiveness and timeliness of the process.
I cannot vote to approve the PCP document in its current form without the development of all
requirements.
Revised to read - A. The manufacturer of the spacer shall submit drawings and bill of materials NP
to the certified simulator for preparing THERM drawing of the spacer according to the
requirements of NFRC 104 [DCC: It makes no sense to assign number 302 to spacer
document, since 300 series deals with solar-optical properties of transparent materials.A. The
manufacturer of the spacer shall submit drawings and bill of materials to the certified simulator
for preparing THERM drawing of the spacer according to the requirements of NFRC 104 [DCC:
It makes no sense to assign number 302 to spacer document, since 300 series deals with solar-
optical properties of transparent materials.


Spacer peer review rules have not been developed. Cannot approve a document that has                NP
procedures that still need to be developed.
Spacer grouping rules have not been developed. Cannot approve a document that has
procedures that still need to be developed.
(COMMENT: See earlier comments regarding the development of the spacer grouping rules.)             NP

Multiple framing systems may be subject to frame grouping rules where the grouped products          NP
shall use the performance values of the simulated frame group leader.
[Placeholder for future frame grouping rules. Alternately, refer to a new technical document,
NFRC 304, which contains this information.]
(COMMENT: See earlier comments regarding the development of the frame grouping.)                    NP
Frame grouping rules to be developed. Once again, we should not be approving the PCP until          NP
all procedures have been developed and approved.
These entities are not accredited. They are approved. There should be a new provision within        NP
the LAP to accommodate the Approved Calculation Entity.
(QUESTION: Does NFRC maintain criteria under which a certification program can become               NP
"recognized"?)
"system documentation" and "paper-trail files" need to be discussed further to determine            NP
specifically what needs to be submitted.
Paragraph C reads: "… The IA will maintain all Documentration files associated with the             NP
fenestration system, as well as the full project files …". Above comments regarding the
documentation files apply here, however, we believe the reference to "full project files" must be
further defined.
We need to determine what the documentation trail files are. No sense burying the Ias in            NP
paper.
CAP sections to be written - see general comments.                                                  NP
(QUESTION: What is the criteria for "qualifying"?) (COMMENT: See earlier comments                   NP
regarding the use of the software tool.)
LAP sections to be written - see general comments.                                                  NP
LAP training and qualification sections to be written - see general comments.                       NP
(COMMENT: See the earlier comments regarding the need to define the documentation trail             NP
and consideration of the frequency of the audits.)
Need to set documentation requirements. The way this is written I'm glad I'm not an IA.             NP

Product Certification – IA Audits                                                                   NP
• IA only audits a randomly selected fraction of product certificates, so language changed to
reflect that. Suggested NFRC choose the fraction, but not to be higher than 10%.

We need to specify the required information and who is responsible for providing it…not just        NP
say “information about the project”.
See Appendiz A - project certificate has not been approved, where is Appendix A?                    NP
Added - Project Certificate shall comply with the format detailed in Appendix A.                 NP
Allow frame grouping on the component level. This would include definition of default (punitive) NP
groups.
It is not possible to approve this document when there are four substantial unresolved issues:    NP
1. Spacer grouping rules
2. Framing grouping rules
3. Development of modified LAP to accommodate the Approved Calculation Entity (ACE)
4. CAP sections to be developed determining conformance for this program.



Frame grouping rules need to be established.                                                      NP
Default framing values need to be determined.                                                     NP
Spacer grouping rules need to be established.                                                     NP
Default spacer values need to be determined.                                                      NP
Software tool for calculations need to be developed and approved.                                 NP
    Comprehensive frame grouping is essential for the new rating program to be practical.           NP
Considering all the various options available in architectural framing systems, there are literally
hundreds-of-thousands of frame product combinations that potentially have to be included. It is
simply not feasible to simulate every possible combination, and the costs would be staggering.
Both new simulation frame grouping rules and optional default frame categories are essential
to reducing this to a realistic number. New frame grouping rules are needed to reduce the
number of potential product lines when doing simulations. Furthermore, the ability to use
default frame categories with default performance values without simulation is needed to
reduce the number of required simulations, particularly for one-time custom extrusions which
may only be used once.
    I also believe the same approach of comprehensive grouping rules and default categories
could be equally applied to spacer submission.
          Discription for Comment #
Being developed by separate committee - Technical committee

Not consisten with the flow chart. Not editorial and to be resolved
by ballot

Policy issue- NFRC BOD

Persusive and Editorial


                   Resolution of Comment


1-LAP




1-LAP




1 - LAP
1&2



1 - Technical committee (Tech. C)

1&2
1,& 2
1
1
1



1
1


1



1 - check
4,2,1,3,3




1&2




1

1

1
1

1



1




2&1




1




1

1




1 - LAP



1&2
1&2&3




1&2




1 - Technical committee (Tech. C)




1 - Technical committee (Tech. C)




1 - Technical committee (Tech. C)
1 - Technical committee (Tech. C)
1 - Technical committee (Tech. C)


1 - LAP
1 & 2 depends on 204 above


1 - CAP
1 - CAP




1 - CAP

1
1 - LAP

1 - LAP
1 - LAP
1 - CAP or PCP


1 - CAP or PCP
1 - CAP




1 & 2 - Label T.G.
1 & 2 - See # C 285
1&2

1&2&3
1 - First two issues need to be deveoped by technical committee.
PCP only informs the user to follow the procedures. APC and CPC
would write language based on NFRC policy.




1 - Technical committee (Tech. C)
1 & 3 for authorization to use defaults
1 - Technical committee (Tech. C)
1 - Technical committee (Tech. C)
1 - Technical committee (Tech. C)
1&2
     Commenter Vote on PCP Informational Draft- By Section




     Commentor Category Section
     CGC 5/22     Neg   1.1

 2
     TK 5/22      Neg   1.1
 6
     CGC 5/31     Neg   1.3

 7
10 CGC 5/31       Neg   1.3
11 CGC 5/31       Neg   1.3
12 CGC 5/31       Neg   1.3
13 CGC 5/31       Neg   1.3
14 CGC 5/31       Neg   1.3
   CGC 5/31       Neg
15                      1.3
   CGC 5/31       Neg   1.3
17
18 DCC 4/20       N/A   1.3
19 DCC 5/22       ???   1.3
   GLC 2/23       N/A   1.3
20
21 MF 5/22        Neg   1.3
     MKW 4/6      N/A   1.3
24
     MKW 4/6      N/A   1.3
25
26 MKW 4/6        N/A   1.3
   MKW 4/6        N/A   1.3



27
29 MKW 4/6        N/A   1.3
30 MKW 4/6        N/A   1.3
31 MKW 5/22       Neg   1.3
33 MKW 5/22       Neg   1.3
34 MKW 5/22       Neg   1.3
35 MKW 5/22       Neg   1.3
     MT 5/22      Neg   1.3

36
     MT 5/22      Neg   1.3

37
38 MT 5/22        Neg   1.3
     TDC 5/22   Neg   1.3

39
     TGR 5/22   Neg   1.3
40
     TGR 5/22   Neg   1.3




41
     TGR 5/22   Neg   1.3

42
     TGR 5/22   Neg   1.3



43
     DCC 5/22         2.3



45
46 DCC 5/22     ???   2.3
   JS 4/20      N/A   2.3




47
     MT 5/22    Neg   2.3

48
     TDC 5/22   Neg   2.3




49
     TK 5/22    Neg   2.3

50
     TK 5/22    Neg   2.3




51
     TK 5/22    Neg   2.3




52
     MT 5/22    Neg   3.1
53
     TDC 5/22   Neg   3.1




54
     DCC 5/22   ???   4.1
56
     GLC 2/23   N/A   4.2
57
     DCC 4/20   N/A   4.3
58
59 CGC 5/31     Neg   5.1
60 DCC 4/20     N/A   5.1
61 DCC 5/22     ???   5.1
62 MKW 5/22     Neg   5.1
     TDC 5/22   Neg   5.1




63
     DCC 4/20   N/A   5.2

64
     MT 5/22    Neg   5.2

66
     GLC 2/23   N/A   6.0
68
     MKW 5/22   Neg   6
69
     MKW 4/6    N/A   6.1
70
     TDC 5/22   Neg   6.3



72
     TK 5/22    Neg   1.2.1.G
80
     TDC 5/22   Neg   1.2.2




84
     CGC 4/12   N/A   1.2.2.1
85
86 CGC 5/31     Neg   1.2.2.1.B
87 MKW 4/6      N/A   1.2.2.1.B
88 MKW 5/22     Neg   1.2.2.1.B
   CGC 5/22     Neg   1.2.2.B




89
90 CGC 5/31     Neg   1.2.2.B
   DCC 5/22     ???   1.2.2.B




91
     MKW 4/6    N/A   1.2.2.B
93
     TK 5/22    Neg   1.2.2.B
95
96 MF 5/22      Neg   1.2.2.C
97 TK 5/22      Neg   1.2.2.C
      CGC 5/22   Neg   1.2.2.D




 98
      DCC 4/20   N/A   1.2.2.D



 99
      DCC 5/22   ???   1.2.2.D



100
101 TK 5/22      Neg   1.2.2.E
    CGC 5/22     Neg   1.2.2.F




102
      TK 5/22    Neg   1.2.2.F
103
105 TK 5/22      Neg   1.2.3
106 TK 5/22      Neg   1.2.3
107 TK 5/22      Neg   1.2.3
    DCC 4/20     N/A   1.2.3.2




108
109 DCC 5/22     ???   1.2.3.2
110 MF 5/22      Neg   1.2.3.2
      DCC 5/22   ???   1.2.3.2.B
111
      DCC 5/22   ???   1.2.3.2.B




113
      GLC 2/23   N/A   1.2.3.2.B
114
      GLC 2/23   N/A   1.2.3.2.C
115
      GLC 2/23   N/A   1.2.3.2.D
117
      GLC 2/23   N/A   1.2.3.2.E
118
      CGC 4/12   N/A   1.2.3.3

119
121 DCC 4/20     N/A   1.2.3.3
126 MKW 4/6      N/A   1.2.3.3.D
      MKW 4/6    N/A   1.2.3.3.F

127
      CGC 5/22   Neg   1.2.3.4
128
      CGC 5/31   Neg   1.2.3.4

129
      TK 5/22    Neg   1.2.3.4
131
132 MF 5/22      Neg   1.2.3.4.A
133 MF 5/22      Neg   1.2.3.4.A&D
      MT 5/22    Neg   1.2.3.4.B



134
135 TK 5/22      Neg   1.2.3.4.B
    MT 5/22      Neg   1.2.3.4.C

136
      JS 4/20    N/A   1.2.3.4.D
137
      MT 5/22    Neg   1.2.3.4.D

138
139 MF 5/22      Neg   1.2.3.4.E
    CGC 5/22     Neg   1.2.4




143
144 MT 5/22      Neg   1.2.4
    TDC 5/22     Neg   1.2.4

145
146 TK 5/22      Neg   1.2.4
147 MF 5/22      Neg   1.2.4.C
      CGC 5/31   Neg   1.2.4.D
148
      MKW 4/6    N/A   1.2.4.D
149
      CGC 5/31   Neg   1.2.4.E
150
      MKW 5/22   Neg   1.2.4.I
151
      CGC 5/31   Neg   1.2.5
152
      MKW 4/6    N/A   1.2.5

154
      MKW 5/22   Neg   1.2.5



155
      TDC 5/22   Neg   1.2.5
156
      CGC 5/31   Neg   1.2.5.A
157
159 MKW 4/6      N/A   1.2.5.A
    DCC 4/20     N/A   1.2.5.B

160
      DCC 5/22   ???   1.2.5.B

161
162 MKW 4/6      N/A   1.2.5.B
163 DCC 5/22     ???   1.2.5.C
      MT 5/22    Neg   1.2.5.C

164
      CGC 5/31   Neg   1.2.6



165
      DCC 5/22   ???   1.2.6




166
      TDC 5/22   Neg   1.2.6

167
168 TK 5/22      Neg   1.2.6
169 TK 5/22      Neg   1.2.6
      DCC 4/20   N/A   1.2.6.B



170
      DCC 5/22   ???   1.2.6.B



171
172 MKW 5/22     Neg   1.2.6.B
174 DCC 5/22     ???   1.2.2.E
175 DCC 5/22     ???   1.2.1.F
    DCC 5/22     ???   1.2.1.G
176
177 DCC 5/22     ???   1.2.1.H
      DCC 5/22   ???   2.1.2
178
      DCC 5/22   ???   2.1.3
179
180 DCC 4/20     N/A   2.1.B
    DCC 5/22     ???   2.2.1




181
      DCC 5/22   ???   2.2.1
182
      DCC 5/22   ???   2.2.1
183
185 DCC 5/22     ???   2.2.1.1
    DCC 5/22     ???   2.2.1.B




186
187 DCC 5/22     ???   2.2.2
188 DCC 5/22     ???   2.2.3
190 DCC 5/22     ???   2.2.4
    DCC 4/20     N/A   2.2.A
191
    CGC 5/31     Neg   2.3.C
195
    DCC 5/22     ???   2.3.C

196
197 MKW 5/22     Neg   2.3.D
198 MKW 4/6      N/A   3.1.1.C
200 DCC 5/22     ???   3.1.A
    DCC 5/22     ???   3.1.B




201
202 CGC 5/31     Neg   3.1.B.i
    DCC 5/22     ???   3.1.B.ii




203
      TK 5/22    Neg   3.1.B.ii
204
      CGC 5/31   Neg   3.1.B.iii
205
      DCC 5/22   ???   3.1.B.iii




206
209 DCC 4/20     N/A   3.1.C
      DCC 4/20   N/A   3.1.C




210
      DCC 5/22   ???   3.1.C




212
213 MF 5/22      Neg   3.1.C
215 DCC 4/20     N/A   3.1.D
      DCC 5/22   ???   3.1.D

216
217 MF 5/22      Neg   3.1.D
      DCC 4/20   N/A   3.3.1.C

220
      DCC 5/22   ???   3.2.2




221
223 DCC 4/20     N/A   3.2.A
224 DCC 5/22     ???   3.2.A
      CGC 5/31   Neg   3.2.A
225
      DCC 5/22   ???   3.2.A




226
      CGC 5/22   Neg   3.2.C

228
229 MT 5/22      Neg   3.2.C
    DCC 5/22     ???   3.3.1.A

230
      DCC 5/22   ???   3.3.1.B



231
      DCC 5/22   ???   3.3.1.C




232
234 CGC 5/31     Neg   3.3.2.A
      TDC 5/22   Neg   4.1.A

236
237 GLC 2/23     N/A   4.1.A.D
238 GLC 2/23     N/A   4.1.E
242 MF 5/22      Neg   4.1.B
    TDC 5/22     Neg   4.1.B
243
    DCC 5/22     ???   4.1.B.1
244
245 MKW 5/22     Neg   4.1.B.1
      DCC 5/22   ???   4.1.B.2

246
      DCC 4/20   N/A   4.1.B.2.iii



247
      DCC 5/22   ???   4.1.B.2.iii




248
252 DCC 4/20     N/A   4.1.C
    DCC 5/22     ???   4.1.C




254
      CGC 5/31   Neg   4.1.D
259
260 DCC 4/20     N/A   4.1.D
    DCC 5/22     ???   4.1.D

261
262 GLC 2/23     N/A   4.1.D
    MKW 4/6      N/A   4.1.D
263
    MKW 5/22     Neg   4.1.D
264
265 MF 5/22      Neg   4.1.D&E
266 CGC 5/31     Neg   4.1.E
    GLC 2/23     N/A   4.1.E
267
    MKW 5/22     Neg   4.1.E



268
      TDC 5/22   Neg   4.1.E



269
270 DCC 4/20     N/A   4.1.E.G
    DCC 5/22     ???   4.1.E.i

271
      DCC 5/22   ???
272                    4.1.E.ii
273 DCC 5/22     ???   4.1.E.iii
    MT 5/22      Neg   4.1.E.iii - iv

274
      MKW 5/22   Neg   4.1.E.vi
275
      GLC 2/23   N/A   4.1.F



276
277 MF 5/22      Neg   4.1.F
278 DCC 5/22     ???   4.1.G
      DCC 4/20   N/A   4.1.H
279
280 DCC 5/22     ???   4.1.H
    DCC 5/22     ???   4.2.B
281
282 DCC 5/22     ???   4.2.B
      TDC 5/22   Neg   4.3.B



283
      GLC 2/23   N/A   4.3.C
284
      DCC 5/22   ???   4.3.D
285
286 MKW 5/22     Neg   4.3.D
287 DCC 5/22     ???   4.3.E
      GLC 2/23   N/A   5.1.A




288
289 MT 5/22      Neg   5.1.B
    MKW 4/6      N/A   6
292
    TDC 5/22     Neg   6.3

293
      TDC 5/22   Neg   6.6.3.1
294
      TDC 5/22   Neg   6.6.3.2
295
      TDC 5/22   Neg   6.6.3.3
296
      TDC 5/22   Neg   6.6.3.4
297
      TDC 5/22   Neg   6.6.3.5
298
299 MKW 4/6      N/A   6.6.3.5.D
    TDC 5/22     Neg   6.6.3.6
300
    TDC 5/22     Neg   6.6.3.7
301
    MKW 4/6      N/A   6.6.6
302
303 MKW 4/6      N/A   6.6.6
      MKW 5/22   Neg   6.6.6
304
      CGC 5/22   Neg   Foreward

305
      JS 5/22    ???   Foreward

306
      JS 5/22    ???   Foreward




307
      JS 5/22    ???   Foreward




308
      JS 5/22    ???   Foreward
309
      MT 5/22    Neg   Foreward

311
      MT 5/22    Neg   Foreward
313
      TDC 5/22   Neg   Foreward



314
      TK 5/22    Neg   Foreward

315
      MKW 4/6    N/A   Foreword

316
      CGC 5/22   Neg   General



317
      DCC 4/20   N/A   General




323
      DCC 4/20   N/A   General
324
      DCC 4/20   N/A   General

325
      DCC 4/20   N/A   General

326
      DCC 4/20   N/A   General




327
      DCC 4/20   N/A   General
328
      DCC 4/20   N/A   General
330
      DCC 4/20   N/A   General

331
      MF 5/22    Neg   General



332
      MT 5/22    Neg   General




334
      MT 5/22    Neg   General




335
      MT 5/22    Neg   General



336
      PM 5/23    Neg   General

343
      TDC 5/22   Neg   General




344
Vote on PCP Informational Draft- By Section                                                                       *
       CGC = Greg Carney, MKW = Margaret Webb , JS = Joel Smith, DCC = Charlie Curcija,                PM
       = Patrick Muessig, TGR = Tracy Rogers , MF = Marcia Falke, NK =Noel King , TG = Tim                        1
       Gehling, TDC = Tom Culp, MT = Mike Turner, TK = Tony Kamber, GLC = Gary Curtis
                                                                                                                  2
                                                                                                                  3
                                                                                                                  4
                                                    Comment                                                      Type
       Last paragraph notes "Products for which label certificates are issued shall be recorded in the      NP
       NFRC Certified Products Directory." Question: Once "products" are listed, can that product
       construction be used for multiple projects by multiple parties?
       The product certification withstanding, use of the component library should be open to those         NP
       who wish to use it.
       Approved Component Laboratory - (QUESTION: Does this mean that NFRC intends to create                NP
       a replacement for the International Glazing Database developed and maintained by the
       Windows and Daylighting Group at LBNL?)
       Glass - (COMMENT: Insert the definition from the other NFRC document.)                               NP
       Deleted - Laboratory Accreditation Program definition.                                               NP
       Deleted - NFRC Inspector                                                                             NP
       Product - (COMMENT: Insert the definition from the other NFRC document(s).)                          NP
       Product Line - (COMMENT: Insert the definition from the other NFRC document(s).)                     NP
       Project Certificate - deleted - The project certificates list the average energy rating values for   NP
       these labeled fenestration systems.
       Total Fenestration Product - (COMMENT: Insert the definition from the other NFRC                     NP
       document(s).)
       Definitions should be included in the Glossary and Terminology document, not here.                   NP
       Definitions should be included in the Glossary and Terminology document, not here                    NP
       Discussion needs to be held regarding the testing requirement of the Component Based Non-            NP
       Residential Product Certification Program.)
       Design Evaluation.                                                                                   NP
       {doors} This seems to be a definition for fenestration products including residential and            NP
       commercial.
       {Specifying Authority} This definition is too narrowly defined and is in the wrong place under       NP
       Definitions.
       {family} What is the point of this definition?                                                       NP
       {Comment on Testing} We have had this discussion already. See previous meeting notes               NP
       from Non Residential Task Group. The reason the flow chart does not include testing is
       deliberate not as a result of not being discussed. Testing will drive up the cost of this program!

       {product} This isn’t a definition. It doesn’t provide clarification on the term.                     NP
       {product Line} This isn’t a definition. It doesn’t provide clarification on the term.                NP
       Approved Component Library: I believe the glazing library is the property of LBNL.                   NP
       Family: What is the purpose of this definition.                                                      NP
       Person: What is the purpose of this definition.                                                      NP
       Specifying Authority: Should not be limited to architects and engineers.                             NP
       Approved Calculation Entity - By requiring an ACE to meet NFRC requirements of the LAP, I            NP
       believe you are limiting the ACE to be an Accredited Laboratory or Simulator. This is not
       acceptable.
       Quality Control Auditor - Since the Specifying Authority definition is restricted to Architects,     NP
       Specifiers, and Project Engineers, I don't believe the SA would be able to provide this type of
       assurance.
       Specifying Authority - Too restrictive, see earlier comment.                                         NP
Definitions                                                                                       NP
• Editorial changes.
• Unused terms deleted.
Glazing Contractor (editorial): Should consider adding "commercial" before "… fenestration        NP
system" to clarify the intent.
Manufacturer: As there is no definition of a "fenestration product" there may be confusion        NP
between this entity and a Glazing Contractor as it pertains to products assembled at a product
site. Clarification is required to differentiate between K-D type "products" that are assembled
on site from a "manufacturer" versus site-built products/systems that are assembled by the
glazing contractor and/or sub-contractors.


Spacer, Spacer System, Spacer Manufacturer: Who is responsible for corner keys, connectors NP
and the sort? These must be included in the thermal analysis yet, by these definitions, they do
not exist.
Certification: From where did Physical Testing and/or Non-Validation come? As noted in the        NP
comment, discussion needs to be had re: the need for and means of testing commercial
fenestration systems. Until this is had and agreed to, this section should be deleted.

Added - D. Frame systems can be subject of grouping rules, as detailed in NFRC 100.               NP
Grouping category shall be indicated for framing systems that are grouped. E. After the IA has
approved framing system, it is automatically assigned # sign indicating approved status.

Deleted rest of section                                                                           NP
A framing system may be granted NFRC approval for inclusion into the Components Library by NP
complying with either the procedure of section 2.3.1 or the procedure of section 2.3.2:
2.3.1 Framing system categories with default performance values
A. A framing system may be assigned to the appropriate generic framing system category from
the list below, and use the default performance values associated with that category.
[Placeholder for future list of frame system categories and the associated default performance
values. Alternately, refer to a new technical document, NFRC 304, which contains this
information.]
B. The manufacturer or supplier of the framing system shall provide system assembly drawings
and material specifications to NFRC, along with the recommended frame system category.
C. NFRC shall confirm the appropriate frame system category, and enter the framing system
information into the Approved Components Library.




Sim labs should submit to an IA … remove sections C & D. New framing grouping rules must          NP
be defined before this program can be approved. What will be the anticipated time it takes to
get data into the library?
Framing System Approval                                                                         NP
• The ability to use default frame categories and default performance values without simulation
is essential for minimizing complexity, especially for custom extrusions which may only be used
once. Language added to clarify the two options: default categories without simulation, or
detailed simulation by a sim lab. Some argue that this issue should be ignored until the
categories have been developed, but it does affect the PCP process, and it is important
enough to include the framework now.
• Some (but not all) manufacturers have expressed concern about peer-review and the
potential to expose some trade secrets. Use of an IA is acceptable when doing simulations,
as long as the ability to use default categories without simulation is also preserved. On the
other hand, an IA may not even be necessary if an independent sim lab is used.


Deleted entire section and reworded. Added "A framing system may be granted NFRC                  NP
approval for inclusion into the Components Library by complying with either the procedure of
section 2.3.1 or the procedure of section 2.3.2."
Added 2.3.1:                                                                                 NP
A. Aframing system may be assigned to the appropriate generic framing system category from
the list below, and use the default performance values associated with that category.
Placeholder for future list of frame system categories and associated default performance
values. Alternately, refer to a new technical document, NFRC 304 which contains this
information.
B. The manufacturer or supplier of the framing system shall provide system assembly drawings
and material specifications to NFR, along with the recommended frame system category.
C. NFRC shall confirm the appropriate frame system category, and enter the framing system
information into the Approved Components Library.



Added 2.3.2:                                                                                 NP
A. An NFRC accredited simulation laboratory shall calculate the framing system values in
accordance with NFRC technical procedures using information submitted by the framing
system manufacturer. The information submitted includes, but is not limited to:
i system assembly drawings/shop drawings
ii system die drawings
iii glazing bite
iv bill of materials
B. The NFRC accredited simulation laboratory shall create framing system models using NFRC-
approved software tools
C. Multiple framing systems may be subject to frame grouping rules where the grouped
products shall use the performance values of the simulated frame group leader.
Placeholder for future frame grouping rules. Alternately, refer to a new technical document,
NFRC 304 which contains this information.
D. The NFRC accredited simulation laboratory shall submit a report to the NFRC licensed IA
chosen by the framing system manufacturer in accordance with the NFRC LAP.
E. The NFRC licensed IA shall review all submitted information for accuracy and once
approved enter the framing system(s) into the Approved Component Library.




See earlier comments on SA. Is the "label certificate" described in C different than the "official NP
label certificate" defined in D?
Specifying Authority Obligations                                                                   NP
• IA only audits a randomly selected fraction of product ratings, so language changed to reflect
that.
• Changed time to provide documentation to 15 days after notification of the audit.
• IA not necessary to review whole-product rating calculation, issue CAR, or issue label
certificate. These can be done directly by ACE.
Replaced - approved component ratings from a component based library database and                     NP
additional software tools with NRFEN
The first thing we should talk about is what products are eligible, then how you do it, who does      NP
it and then the label/label certificate…
This has all been spelled out completely in Section 2. Why would we repeat it here, other than        NP
trying to confuse ourselves?
(COMMENT: See earlier comments regarding the documentation trail and audits.)                         NP
Welcome to the 21st century! Lets skip “paper-trails” and establish “electronic-trails”.              NP
Welcome to the 21st century! Lets skip “paper-trails” and establish “electronic-trails”]              NP
The documentation trail requirements need to be established.                                          NP
Documentation-Trail Audit                                                                             NP
• Clarified that only a fraction of product certificates are selected for audit.
• Removed notification of code official. Although I agree one major purpose of NFRC rating is
for code use, it is not the role of an IA to get into direct enforcement. It may also be a waste if
the project is still at an early phase and the specifying authority takes corrective action.
I don’t understand why would specifying authority be responsible for audit costs. I think that       NP
audit costs should be built inot the program cost and charged once through the certificate fee.
This way it increases bureaucracy.
Auditing expenses should be built into the ACE licensing agreement with NFRC. Random                 NP
samplings can be done on their certified projects. The market will not support Sas being
responsible for paying for random audits.
(Comment: This section needs to be rewritten to fit the component based program and the              NP
Role of the Design Professional .)
This whole section is over written and unnecessarily bureaucratic. It does not need to be this       NP
complicated in order to document the challenge procedures.
This section is over-written and difficult to follow. It seems excessively bureaucratic. I believe   NP
the process can be described in much simpler terms.
Challenge Procedure                                                                                  NP
• Since an IA did not issue the specific label certificate, changed language to just make it
general that any IA is used for the challenge process.
• Editorial changes
The CPD could also serve as the data base where ratings of previous component                    NP
configurations could be accessed on future projects thus
Role of Specifying Authority:                                                                    p, NP
• Editorial changes.
• SA does not contract IA to issue label certificate, which can be done by ACE.
• IA only audits a randomly selected fraction of product ratings, so language changed to reflect
that.
• Removed language in section 1.2.2.1 about participating in other certification programs “not
related to energy performance.” Certifying air leakage under AAMA/WDMA/CSA
101/I.S.2/A440 could be considered "energy related" since it is required in IECC and ASHRAE.
This language is not really necessary, anyway.

I honestly do not understand the intent of this item and would ask if Bipin or Carl can explain      NP
the intent.
(QUESTION: What does this mean -- what specifically is it attempting to address?)                    NP
{procedures} Is this a restraint of trade?                                                           NP
This appears to be a restraint of trade.                                                             NP
Second bullet "Detailed Information on Spacer System." Previous drafts and discussions               NP
related to the spacer system information have included the sealant materials and dimensions.
While the information has been removed from this draft, it is likely to return in response to this
review. In order to avoid multiple simulations related to minor variations in the sealant
dimensions (silicone secondary seals for structural silicone glazing applications for example),
we recommend default sealant system (dimensions) be established for the various spacer
systems that are entered into the spacer database.


3rd bullet - (QUESTION: What is meant by "Detailed information"?)                                    NP
Added - in writing and added - and identification of the insulating glass fabricator including       NP
name and contact informationafter 1st bullet and added - and spacer manufacturer including
name and contact information after 2nd bullet and added - and identification of the framing
system manufacturer/fabricator including name and contact information after 3rd bullet.

This can be provided by the IG manufacturer along with the other information requested.. I           NP
don’t see the need to list it separately.
Deleted specific requirements - added "Component information required for the software to            NP
perform the calculation."
Requires IG certification.                                                                           NP
Deleted.                                                                                             NP
Provides the first reference to the "… whole product rating specification data retention     NP
(Documentation Trail) …". The requirements of the documentation trail and individual project
requirements have yet to be defined. As we have mentioned in numerous previous meetings,
the contractural nature of the commercial construction industry and well established
documentration requirements of purchase orders, acknowledgements, shipping case tags, etc.,
are an ongoing part of the commercial fenestration industry. The subcommittee needs to
carefully consider the requirements of the documentation trail. We strongly recommend a
minimal audit program where a small percentage of projects require submittal of a limited
number of defined documents. (NOTE: The documentation trail is mentioned in several
sections of the draft and needs to be properly discussed and defined before the product
certification program moves forward for adoption.)


I disagree that there is a need for IA for whole product certification. I believe that it is much NP
more cost-effective and less cumbersome if random selection of whole product
certifications/label certificates are reviewed by IAs on an annual basis, while ACE is allowed to
issue label certificate in real-time from the component library.
I disagree that there is a need for IA for whole product certification. I believe that it is much NP
more cost-effective and less cumbersome if random selection of whole product
certifications/label certificates are reviewed by IAs on an annual basis, while ACE is allowed to
issue label certificate in real-time from the component library]
Deleted.                                                                                             NP
Last paragraph reads "Additional requirements may be established by NFRC as necessary to NP
assure continued program credibility." In lieu of such an open ended statement at this location,
we would recommend a general statement in the Forward stating that program requirements
may be modified at times based on committee and membership actions.

Deleted - Additional requirements may be established by NFRC as necessary to assure                  NP
continued program credibility.
This needs to be definitive in terms of the definition of the role.                                  NP
This needs to be definitive in terms of the definition of the role.                                  NP
Deleted - including but not limited to the following functions.                                      NP
I have deleted most of peer review, expert review by certified simulators, etc. tasks as             NP
unnecessary and complex. It is far more effective to have certified simulator perform
simulation and upload information and be done with it, rather than developing the whole new
Rube Goldberg type of process, where there are additional layers of bureaucracy and
oversight.
Deleted C, D & E - This is not the place to describe details of spacer grouping                      NP
Peer review for spacer's info into bucket.                                                           NP
Revised to read - Submitting spacer details to the certified simulators to simulate their
performance for upload to the NFRC approved component database.                                      NP
 I have deleted most of peer review, expert review by certified simulators, etc. tasks as            NP
unnecessary and complex. It is far more effective to have certified simulator perform
simulation and upload information and be done with it, rather than developing the whole new
Rube Goldberg type of process, where there are additional layers of bureaucracy and
oversight.]
(Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. Isn’t     NP
this the responsibility of the simulator?)
(Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. This is   NP
the responsibility of NFRC.)
(Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. This is   NP
the responsibility of NFRC.)
(Note: This is not a manufacturer/supplier “responsibility” and should not be listed here. This is   NP
the responsibility of NFRC.)
Beginning with this section and continuing throughout the draft, I do not believe the information    NP
on the framing considerations have properly addressed the task group flow chart or the text
provided by Joel Smith and Tony Kamber.
This is not the place to describe details of spacer grouping.                                        NP
{review} Peer or expert?                                                                             NP
{[*language in square bracket is suggested task group language not in the flow chart ]} I           NP
support the inclusion of this clause. Provides independent in the selection procedures.

A framing system manufacturer should have the right to simulate framing systems in-house            NP
and then have the work checked by an accredited simulator.
Added - F. Choose to use only component product databases and simulation tools under the            NP
NFRC program for design evaluation without the intent of product or project certification and
labeling.
Added "Framing manufacturer may elect to perform the calculation itself and forward for (end?) NP

Accredited simulator to do sims not acc lab.                                                        NP
Accredited simulator checks his own work????                                                        NP
I'm assuming this section applied to Product Line Simulations (see section 4.1.H). I don't  NP
believe "system dimensional tolerances" is appropriate. Maybe "nominal system dimensions".
Also, what is the procedure for adding a section to a product line? (i.e., adding a 4" wide
curtain wall vertical mullion to a standard 2 1/2" curtain wall system.)
Deleted - and shop drawings                                                                         NP
I believe the "simulation model" should match the NFRC default gateway size for that product        NP
category. Is this supposed to be provided in the form of an elevation drawing?

Expert Review.{{Peer review is used in the flow chart but expert review is also used at times, NP
the committee should select one only.}}
Delete this section - not necessary. Challenge procedures are in place to handle numbers that NP
appear erroneous. The manufacturer has already contracted with an Accredited
Laboratory/Simulator to prepare the data.
Conflicts with D of 1.2.4.                                                                          NP
We question the role of the IA in the whole product certification based on calculations with        NP
materials from the databases. Once the glass, spacer and framing system(s) have been
documented in the project specifications, a calculation entity combines the specified products
and framing system and calculates the thermal and optical performance values. The cost of
having the IA check to see if the calculation entity used the specified products in the calculation
is unnecessary. We believe the cost and role of the IA can be dramatically reduced by the
properly designed software using glass, spacer grouping and frame grouping opportunities.


Rework per comments on 1.22, 1.2.2.B, 1.2.3.4.B, 1.2.3.4,C, 1.2.3.4.D and 1.2.3.5.                  NP
Role of IA                                                                                          NP
• IA only audits a randomly selected fraction of product ratings, so language changed in
multiple places to reflect that.
Deleted but not limited to                                                                          NP
Conflicts with E of 1.2.3.4.                                                                        NP
(QUESTION: Do the current IA's have staff members that are prepared to approve framing              NP
component performance values?);
{database} I didn’t think IA’s were part of the component approval process. The IA comes into       NP
play when certification is required.
(COMMENT: See earlier comments related to the definition of the documentation trail and the         NP
level of product / project audits);
The IA is not part of the component approval procedure per the Visio Flow Chart identified as       NP
Draft IV, November 29, 2005.
Added - D. Perform component-based fenestration product calculations for design evaluation          NP
purposes when product/project certification may or may not be intended.
{is responsible for meeting the requirements in the LAP and PCP including, but not limited to,      NP
the following functions:} Thought the intent was that the ACE was NOT subject to the LAP.

(Comment: Need to create requirements for ACE)                                                      NP
This is a substantial issue and will affect the cost-effectiveness and timeliness of the process.
I cannot vote to approve the PCP document in its current form without the development of all
requirements.
Role of ACE                                                                                      NP
• Included that ACE can directly issue label certificate.
(COMMENT: See earlier comments regarding the approval process, use of the software tool          NP
and whole product calculations.)
approved (or authorized)                                                                         NP
This is not necessary. Independence criteria needs to be maintained only to submit               NP
component level data. Manufacturers or any other trained entity should be allowed perform
whole product assembly based on approved components.
Deleted - This is not necessary. Independence criteria needs to be maintained only to submit     NP
component level data. Manufacturers or any other trained entity should be allowed perform
whole product assembly based on approved components
See comment on approved versus accredited..                                                      NP
Added - NRFEN                                                                                    NP
You should not have to be an ACE to utilize the software for preliminary design purposes.        NP
Framing manufacturers should be allowed to use the software for their own product lines.
Component Manufacturers should also be allowed to be an ACE.
2nd paragraph - deleted - Specifying Authorities and Component Manufacturers participating in NP
the NFRC Component-Based Fenestration Product Certification Program shall use accredited
Simulation Laboratories or an accredited Simulator for fenestration system frame modeling
files.
2nd paragraph - revised to read - B. Simulating spacers in accordance with NFRC approved         NP
programs
C. Inputting framing system and spacer information into the component database, upon the
authorization of the framing and /or spacer manufacturer; including all necessary information,
based on which IA can perform appropriate review
Role of sim labs                                                                                 NP
• Removed language for Specifying Authority and component manufacturers that is redundant
with previous language in Sections 1.2.2 and 1.2.3.
2nd paragraph - deleted - including but not limited to the following functions                   NP
2nd paragraph - B - deleted to the IA                                                            NP
Accredited simulation laboratory shall be responsible only for certified simulations of          NP
components and submission of components to the component database. ACE is responsible
for whole product calculations. This does not preclude accredited simulation laboratories to
have ACEs on staff.
Deleted - component-based .... simulation tools. Added - This is not necessary. Independence NP
criteria needs to be maintained only to submit component level data. Manufacturers or any
other trained entity should be allowed perform whole product assembly based on approved
components
IA is not part of the component approval procedure.                                              NP
Added - certified simulations and testing services and reports                                   NP
Added - labels and                                                                               NP
Added - Maintains an online real-time listing of component performance (i.e., U-factor, SHGC,    NP
VT) for frame systems, glass and glazing layers, and spacers.
Added - conducts round robins, and inspects laboratories, IAs                                    NP

deleted section - This is already spelled out in 302 document and should not be repeated here    NP
Revised to read - Approved glazing shall be uploaded by LBNL into the Glazing Component          NP
Library and the # sign added in the library to signify approved status.
This is already spelled out in 302 document and should not be repeated here.                     NP
Revised to read - A. The manufacturer of the spacer shall submit drawings and bill of materials NP
to the certified simulator for preparing THERM drawing of the spacer according to the
requirements of NFRC 104 [DCC: It makes no sense to assign number 302 to spacer
document, since 300 series deals with solar-optical properties of transparent materials.A. The
manufacturer of the spacer shall submit drawings and bill of materials to the certified simulator
for preparing THERM drawing of the spacer according to the requirements of NFRC 104 [DCC:
It makes no sense to assign number 302 to spacer document, since 300 series deals with solar-
optical properties of transparent materials.
Added - B. The manufacturer of the spacer shall submit one physical sample, at least 1 ft. long. NP

Added - E After the IA has approved spacer, it is automatically assigned # sign indicating          NP
approved status..
Deleted                                                                                             NP
Revised to read - Certified simulator shall upload THERM model of the spacer to the spacer          NP
component library and NRFEN shall notify IA that the spacer is pending approval.D. Spacers
can be subject of grouping rules, as detailed in NFRC 104. Each spacer shall be assigned
grouping category (automatically, based on the effective conductivity of the spacer assembly),
which will allow manufacturer to later select either actual spacer performance or grouped
spacer performance.
Deleted                                                                                             NP
Deleted                                                                                             NP
Deleted                                                                                             NP
It makes no sense to assign number 302 to spacer document, since 300 series deals with solar- NP
optical properties of transparent materials.
(QUESTION: Why are "NFRC Expert Reviewers" needed if the work has been done by a              NP
simulator?)
Revised to read - The NFRC accredited simulation laboratory shall upload the framing system NP
model into the framing component library, and NRFEN shall notify IA of the pending review and
approval
Expert Reviewers - this term needs to be defined.                                                   NP
{LAP} This is an ongoing inconsistency within this document.                                        NP
Added - thermal and solar-optical                                                                   NP
Revised to read -                                                                                   NP
iv. Identification of Framing System manufacturer and model #
v. Fenestration product operator
vi. Layout of framing system model #s for the fenestration product
vii. Identification of the permit issuance agency and contact information
Deleted - but not limited to                                                                        NP
Revised to read -                                                                                   NP
a. number of lites
b. glass manufacturer and model #
   c. gas-fill (if applicable)
e. coated surface placement
g. gap between lites
h. glazing bite
deleted - shall be certified by nationally recognized certification agency which is recognized by   NP
NFRC.
(QUESTION: Does NFRC maintain criteria under which a certification program can become               NP
"recognized"?)
Revised to read -                                                                                   NP
a. Spacer manufacturer and model #
b. Secondary sealant details
c. Primary sealant details
d. Spacer position wrt. the glazing edge
Why do we need paper-trail in the age of electronic filing?                                         NP
This is very confusing! How can IA approve label certificate if it is going to receive files 10   NP
days after the certificate has been issued? Let me expose how I see this process working;
There are two potential scenarios, 1) new product line (PL) certification (equivalent to the
present-day certification/re-certification, and 2) new product within the existing product line
(equivalent to present-day addendums). In the first case, Manufacturer/Specifying authority
sends documentation (hard copy or electronically) to the IA, IA creates entry in the NRFEN for
the new PL, certified simulator uploads simulation data in NRFEN, test lab uploads test data in
the NRFEN (all associated with the entry for the PL that IA created earlier), NRFEN performs
logical error check and if everything is OK, issues direction to IA that PL needs approval (there
is a firm deadline associated with this, so that IA can not unnecessarily hold certification, IA
reviews everything for all inconsistencies and errors, confirms documentation with the uploads
and approves PL. PL is given equivalent of # sign and after that ACE can issue label
certificates involving this PL.
In the second scenario, ACE simply applies different glazing and spacer options to
the approved PL. No further interaction with IA is required. Certificates are issued
on the spot to the ACE and forwarded to the Specifying Authority. In case of errors
or non-validation, NRFEN and/or IA issues notification to the ACE and Specifying
Authority about problems and informs about correction action required. If the
corrective actions are not done within the prescribed amount of time, certification
fee is forfeited and new certification has to be initiated.




Revised to read - The Specifying Authority shall select an NFRC Licensed IA prior to the Label NP
Certificate issuance. The Specifying Authority shall submit all system documentation either as
a hard copy or electronically, identified in the PCP (“paper-trail” files [DCC: Why do we need
paper-trail in the age of electronic filing?]) to the selected IA within ten (10) days of issuing the
Label Certificate [DCC: This is very confusing! How can IA approve label certificate if it is
going to receive files 10 days after the certificate has been issued? Let me expose how I see
this process working; There are two potential scenarios, 1) new product line (PL) certification
(equivalent to the present-day certification/re-certification, and 2) new product within the
existing product line (equivalent to present-day addendums). In the first case,
Manufacturer/Specifying authority sends documentation (hard copy or electronically) to the IA,
IA creates entry in the NRFEN for the new PL, certified simulator uploads simulation data in
NRFEN, test lab uploads test data in the NRFEN (all associated with the entry for the PL that
IA created earlier), NRFEN
 performs logical error check and if everything is OK, issues direction to IA that PL needs
approval (there is a firm deadline associated with this, so that IA can not unnecessarily hold
 certification, IA reviews everything for all inconsistencies and errors, confirms documentation
 with the uploads and approves PL. PL is given equivalent of # sign and after that ACE can
 issue label certificates involving this PL. In the second scenario, ACE simply applies
different
glazing and spacer options to the approved PL. No further interaction with IA is required.
Certificates are issued on the spot to the ACE and forwarded to the Specifying Authority.
In case of errors or non-validation, NRFEN and/or IA issues notification to the ACE and
Specifying Authority about problems and informs about correction action required. If the
corrective actions are not done within the prescribed amount of time, certification fee is
forfeited
and new certification has to be initiated]. The IA will maintain all files associated with the
fenestration system, as well as the full project files, for verification purposes for a period of two
(2) years. Electronic copy becomes permanent record on an NFRC server. [DCC: Where is it
 specified how is payment for the label certificate to NFRC handled?]

Issue a PRELIMINARY label Certificate.                                                           NP
See above.                                                                                       NP
Revised to read - Label Certificate is issued for approved Product lines [DCC: see above] by     NP
the NRFEN to ACE, which is then forwarded to the Specifying Authority, unless Specifying
Authority is ACE itself, in which case forwarding is skipped.
Issue a FINAL label Certificate.                                                                 NP
I have small corporation business for 11 years, but I never obtained any “business license”.     NP
What business license are we talking about? DUNS number? State Department of Labor
code, Federal ID number? What? Please be specific.
Revised to read - A. Training shall be available to anyone seeking certification as an ACE and   NP
is employed by an organization. Specific requirements for training and qualifications are set
forth in the LAP [DCC: I would like to offer some ideas for LAP: ACE shall complete a 4 hour,
NFRC-sanctioned training either on the use of NRFEN, which can be taken either in person at
the scheduled location or on line, which includes online testing.] ACE shall pass NFRC
supplied exam. For additional details see LAP.
 [DCC: I think that this should not be in PCP. This is LAP language]
B. Upon the completion of the NRFEN training and passing exam, ACE shall sign a license
agreement with the NFRC, after which ACE shall be qualified to generate bid and certification
level reports.


I think that this should not be in PCP. This is LAP language.                                    NP
Deleted                                                                                          NP
QUESTION: What is the criteria to obtain the license?) (COMMENT: See earlier comments       NP
regarding the use of the software tool.)
Revised to read - A NFRC license is attainable to an Approved Calculation Entity, ACE, who  NP
desires to calculate the performance rating values of component-based whole product systems
in accordance with NFRC 100 using NRFEN [DCC: ACE only needs to know how to use
NRFEN, not other NFRC-approved software tools, like THERM or WINDOW]. Deleated B & C

There needs to be another category -- Possibly Design Calculation Entity that would allow        NP
anyone interested in using the calculation software tool for design & development to gain
access and use.
This section would limit the market's ability to obtain pre-bid performance numbers.             NP
Revised to read - A. Qualification requirements for the approval of ACE shall require that the NP
agency employ at least one full-time NFRC ACE on staff. The ACE shall be responsible for all
NFRC reports issued
Revised to read - Upon signing an NFRC license agreement, the ACE shall be registered to    NP
utilize the NRFEN and shall be issued a licensee number. The licensee number authorizes the
ACE to generate the NFRC-sanctioned reports for the Specifying Authority.

Revised to read - ACE shall be employed by a business organization, further referred to as         NP
“organization” that maintains a business license recognized by the State or Province in which
its staff are employed [DCC: I have small corporation business for 11 years, but I never
obtained any “business license”. What business license are we talking about? DUNS
number? State Department of Labor code, Federal ID number? What? Please be specific].
The NFRC licensee number shall be tied to both the individual staff and organization, where
organization shall hold organizational license, while individual shall hold individual license, in
the form of a sub-license to the organziation (e.g., Organization may hold License # CAR-000,
while individuals would hold license numbers CAR-001, CAR-002, and so forth). In the event
that the individual originally obtaining the NFRC licensee number is no longer employed by the
organization, the organization shall provide replacement individual, subject to the completion of
the course and passing of the exam, and shall assign the same license number to the
replacement individual.
If the replacement individual has not been provided in the allotted time frame, the license that
 individual number shall be deactivated. If the organization is left without any ACE and has not
provided any replacement in the allotted time period, or if the organization is no longer a legal
entity, the organizational license shall expire. Organization and at least one ACE shall
re-register with the NFRC for a new licensee in order to continue to perform ACE-related
activities and issue NFRC-sanctioned reports. It shall be the responsibility of the organization
to
 advise NFRC of any or all business changes that would cause a licensee to re-register or to be
 de-listed. (For Additional information, see the LAP)


(COMMENT: See earlier comments regarding the use of the software tool)                           NP
Product Certification - Specifying Authority participation                                               NP
• Removed need to contract IA at start. IA only necessary if randomly selected for audit.

Or select another component or component supplier                                                        NP
60 days is pretty long, maybe 45                                                                         p
Too many new "participants".                                                                             NP
Product Certification – Issuance of label certicates                                                     NP
• Changed language to reflect that label certificate can be issued by sim lab or ACE.
Revised to read - 1. Label Certificates can be issued from the NRFEN to the Specifying                   NP
Authority by ACE utilizing the process specified in Section 2..
If this is the process then what does the IA add to the process.                                         NP
Revised to read - NRFEN allows the ACE, to access component database online, calculate the NP
thermal and solar-optical performance ratings for the whole product, and generate a label
certificate or bid-level report.
It was not clear here if signing is required prior to ANY label certificate issuance. If it is, then I   NP
am strongly against it as an unnecessary burden to everybody. License agreement should be
signed once and maintained unless there is a breach of agreement. I have provided specific
language addressing that.
Revised to read - iii. The ACE shall be contracted to generate bid-level reports or label              NP
certificates using NRFEN.
iii. The Specifying Authority may either print out the label certificate from the NRFEN directly or
may authorize ACE to do so. In either case, the Specifying Authority shall sign and execute the
license agreement with NFRC before issuance of any label and/or project certificates. The
license shall be maintained with NFRC subject to the periodic review by NFRC, but it shall not
be necessary to re-sign license agreement prior to follow-up label certificate issuences. [DCC:
It was not clear here if signing is required prior to ANY label certificate issuance. If it is, then I
am strongly against it as an unnecessary burden to everybody. License agreement should be
signed once and maintained unless there is a breach of agreement. I have provided specific
language addressing that]


NOT!! This is bureaucratic and unnecessary.                                                              NP
Revised to read - The [DCC: NOT!! This is bureaucratic and unnecessary] documentation                    NP
about the products contained in a label certificate shall be documented (i.e., bill of sales,
purchase orders, specifications, etc.) and maintained by Specifying Authority, with the most
important details maintained in NRFEN.. IA shall conduct random audits of these systems to
ensure that the system is accurately reflected in the label certificate issued, and complies with
the requirements of the PCP. [DCC: To heck with the paper documentation! Who needs piles
of paper at this day and age!?]
(QUESTION: Why would there be a situation where a system could not be certified using the                NP
simulation and calculation tools?)
{Comment on Testing} I agree.                                                                            NP
Revised to read - Physical testing shall be performed on a very limited basis and no more than NP
for 1% of the systems considered. The IA shall inform Specifying Authority when physical
testing needs to be performed
Question: Should this be Specifying Authority?                                                           NP
{Comment on Testing} Discussion has been had. See previous comments on this item.                        NP
Testing may occur on challenged submissions.
Physical Testing indicates that's only products which cannot be simulated will be tested.                NP
Therefore the two clauses are inconsistent with each other.
Test only non-simable products but non validation says to sim.                                           NP
Deleted entire section on non-validation.                                                                NP
I don’t thinkl we want the Specifying Authority to be the one to “elect” whether to the calcs…it         NP
should be the IA or NFRC …someone independent
This clause assumes that products will be tested whereas testing requirements have not been              NP
determined for the CMA program. A the October 5, 2005 meeting in Atlanta, the task group
agreed that testing would not be required as it would drive up the cost of certification.
Product Certification – Non-validation                                                          NP
• If no testing is required except when a product cannot be simulated, then the section on non-
validation is not relevant. (But I do realize the testing issue is not yet resolved.)

This comment is just repeated here.                                                                 NP
Revised to read - A. The IA shall notify in writing the Specifying Authority, ACE, Simulation and NP
the Testing Laboratory of the non-validation. These parties shall attempt to establish reasons
for the non-validation.
Revised to read - B. These parties shall have ten no more than 30 calendar days to identify the NP
reason(s) for the non-validation.
Added - at the expense of the component manufacturer                                            NP
The SA will not agree to bear the burden of these costs. Also … who is responsible if the           NP
softare yields wrong ratings? The owner/architect will be looking for fault.
(Comment: Discussion needs to be ….) - Physical testing is not required at this point.
Which committee is responsible for the decision determining the values for certification?           NP

We need to define recertification requirements to individual products rated and certified using NP
the component based ratings …and what if a manuf or specifying authority wants to recertify a
system that was used previously…it isn’t an everyday issue, but “old” extrusions sometimes get
reused.
What about recertification of the buckets?                                                          NP
Changed "approved by" to "subject to"                                                               NP
All of frame grouping rules should be spelled out in one place, not like this one at a time.        NP

Revised to read - at the expense of the component manufacturer                                      NP
Revised to read - Product performance shall be calculated using NFRC-approved software tool NP
NRFEN and from approved components as specified in Section 2.
Rest of section deleted                                                                        NP
Project Certification                                                                          NP
• Included language that allows area-weighted averages for U and SHGC to be reported for the
whole project. This info is often useful for U and SHGC, but not pertinent for VT. This should
be allowed, although not mandatory.
We need to specify the required information and who is responsible for providing it…not just        NP
say “information about the project”.

Deleted                                                                                             NP
See Appendiz A - project certificate has not been approved, where is Appendix A?                    NP
Added - Project Certificate shall comply with the format detailed in Appendix A.                    NP
(Comment: This appears to require the paper review/audit of every project. Discussion during        NP
previous task group meetings cautioned that 100 percent audit of the paper-trail will result in a
massive accumulation of documents that will quickly become unmanageable for the IA’s.
Contractual requirements of the commercial construction process serve as assurance for the
parties involved. A random paper-trail audit of 10 percent of the non-residential would be
reasonable.)
It is not appropriate for the Ias to notify the "code official (permit granting agency)".           NP
This whole section is over written and unnecessarily bureaucratic. It does not need to be this NP
complicated in order to have meaning.
Parties to Appeal process                                                                           NP
• Clarified language about IA’s involvement (IA did not issue certification, only involved with the
original challenge.)
Submissions by parties                                                                              NP
• There appears to be redundant information which needs to be cleaned up.
Submissions by parties                                                                              NP
• There appears to be redundant information which needs to be cleaned up.
Submissions by parties                                                                              NP
• There appears to be redundant information which needs to be cleaned up.
Submissions by parties                                                                              NP
• There appears to be redundant information which needs to be cleaned up.
Submissions by parties                                                                            NP
• There appears to be redundant information which needs to be cleaned up.
The ACE does not issue the label certification so don’t see the need for this condition.          NP
Submissions by parties                                                                            NP
• There appears to be redundant information which needs to be cleaned up.
Submissions by parties                                                                            NP
• There appears to be redundant information which needs to be cleaned up.
I would support a permanent Appeals Committee. This committee should have balanced                NP
representation.
I would like more discussion on the designation of the appointees.                                NP
I would like more discussion on the designation of the appointees. This should include            NP
balanced representation.
The draft document Forward references several situations that have not been fully determined      NP
and/or defined at this time. The document Forward should be deleted until such time as the
program is fully defined.
1st paragraph - …. ultra-violet (UV) performance, and comfort performance. {{Comment was    NP
received that the last sentence should be deleted because the document should not speculate
on future developments.}}
2nd paragraph- …. by an NFRC Independent Certification and Inspection Agency (“IA”). The          NP
requirements of the rating, certification, and labeling program (the "Certification Program") are
set forth in the most recent version of the NFRC Product Certification Program (the “PCP”), as
amended, updated or interpreted from time to time. Through the Certification Program and its
companion laboratory accreditation program (the "Accreditation Program") , set forth in the
NFRC Laboratory Accreditation Program (the “LAP”), as amended, updated or interpreted from
time to time, and IA licensing program (the "IA Program"), set forth in the most recent version
of the NFRC Certification Agency Program (the “CAP”), as amended, updated or interpreted
from time to time, NFRC intends to ensure the integrity and uniformity of NFRC ratings,
certification and labeling by ensuring that specifying authorities, testing and simulation
laboratories, and IAs adhere to strict NFRC requirements.


3rd paragraph - …. manufacturer/component manufacturer/specifying authority shall rate a            NP
product to be certified for mandatory NFRC rating procedures. At present, a
manufacturer/component manufacturer/specifying authority may elect to rate products for U-
factor, solar heat gain coefficient, visible transmittance, air leakage, condensation resistance,
or any other procedure adopted by NFRC, and to include those ratings on the NFRC label
affixed to its products (or the NFRC Label Certificate for component based products) . U-factor,
SHGC and VT, AL, and CR rating reports shall be obtained from a laboratory, which has been
accredited by NFRC in accordance with the requirements of the LAP. The rating shall then be
reviewed by an Independent Certification and Inspection Agency (IA) and/or peer view
committee which has been licensed/approved by NFRC. NFRC-licensed IAs also review label
certificate format and content, conduct in-plant inspections and/or paper trail reviews for quality
assurance in accordance with the requirements of the CAP, and issue a product Certification
Authorization Report (CAR) , or an NFRC Label Certificate for component based products and
 attachment


4th paragraph - …. Certified Products Directory (the “CPD”), listing product lines and individual NP
products selected by the specifying authority for which product
"air leakage" should be removed from this component based certification program. To my            NP
knowledge, there is not a software tool to certify this performance. This program should be
limited to what can only be computer simulated.
"NFRC-licensed" IAs also review label certificate format and content - certificate should be a    NP
set format. So, there should be no need to review.
Editorial changes.                                                                                NP
IA not necessary to review whole-product rating calculation, issue CAR, or issue label
certificate. These can be done directly by ACE.
IA does not audit every product rating, only a prescribed fraction.
The forward describes a process in which numerous issues have yet to be decided. As a result NP
I think it would be prudent to write the forward in accordance with the final agreed upon draft.
Perhaps we should differentiate between plant fabricated and site-built ie. Store fronts tend to    NP
be plant fabricated (much like residential products) while curtainwalls are field glazed or site-
built.
During task group and subcommittee meetings, discussion has been held concerning the                NP
requirement for an area-weighted U-Factor and Solar Heat Gain Coefficient (SHGC) for a
project. We believe this should be allowed as a part of the program but not a requirement on
all projects.
Interchanging use of terms "peer review" and "expert review" is confusing to me. I think that it    NP
is cleaner to use terms "certified simulator" and "peer review". We have been using terms
"certified simulator" and "accredited lab" for work where certification of the simulator and
accreditation of lab is necessary, for long time, so there is no need to invent new terminology
for the same thing. KISS principle.
Peer review should be allowed only for glass entries, in line with the current practice. Again, NP
KISS principle.
Spacers and frame components require identical skills and knowledge for simulation (albeit,     NP
spacers are smaller and less complex), so they should both be done by certified simulators and
we should be all spared of peer review of any of that.
IAs should BE "directly" involved in all component submittals that require certified                NP
simulators/accredited labs (i.e., spacers and frames) and they should provide approval of
these.
IAs should NOT be involved (other than random checks) in any portion of the process after the NP
components had been approved (i.e., use of NRFEN, generation of label certificates, etc.).
This is important to keep the process as bureaucratic-free as possible. This is especially
important for bid-level reports. Simplicity of using NRFEN and thorough documentation that is
available through NRFEN archiving system, that provides easy trace-back in case something
needs to be checked, will allow for this simplified route.


Allow frame grouping on the component level. This would include definition of default (punitive) NP
groups.
Provided for clarity in the process of ACE (relationship between company and individual and      NP
their relationship with NFRC).
Provided detailed vision of the flow from component simulation to upload to validation to IA     NP
approval to the role of ACE to the use of NRFEN to the issuance of label certificate and finally
to what happens if there are problems in between.
Initally the glass buckets was done by peer review and the spacer & frame buckets the NFRC NP
certified ratings meaning that simulation and some degree of testing was done. I therefore
thought that further testing would not be required. What are the testing requirements under the
current scenario?
This is back-up to my "Do Not Approve" ballot submitted on the component-based PCP                  NP
information draft. I feel that the proposed language in the certification program is not functional
in the commercial construction market. The "Specifying Authority" (SA) is limited by definition,
and other requirements, to be an Architect, Specifier, or Project Engineer. The responsibilities
of this program place undue burdens on the SA. As a quick recap of the proposed program,
the SA authority must:
-contact an ACE to perform calculations (prebid & post construction)
-the SA must supply very detailed information to an ACE in order for this calculation to be
made
-verify that IG units supplied to the jobsite are certified by an IG certification program
-enter into a contractural relationship with an IA to review project documentation and audit their
project/paper trails ... all of this in order to obtain an official label certificate
-enter into another agreement with NFRC to use the NFRC certification mark
-must pay any fees associated with a Documentation-trail audit if they are selected
In my opinion, this type of responsibility will not be accepted by those defined as "Specifying   NP
Authorities". Some recommendations to include in the rewrite are:
-broaden the definition of the SA
-have the SA enter into an agreement with an ACE
-have an ACE enter into an agreement with NFRC and IA. The IA would then audit the ACE's
activities. The licensing fees associated with an ACE could be structured to cover costs of
random audits (possibly 10%)
-have the SA enter into an agreement with NFRC in order to obtain the certificate
In conclusion, I propose that a rewrite be done on this informational draft and that it be re-    NP
issued as an informational draft to receive further comments. I can not provide an approval
vote for this program until these major issues are resolved and "to be developed" sections are
final.
The following comments are referenced to the first occaision that they appear in the draft NP
document. Most of the items appear repeatedly and our comments would also apply to related
additional sections of the document as they occur.
    Comprehensive frame grouping is essential for the new rating program to be practical.           NP
Considering all the various options available in architectural framing systems, there are literally
hundreds-of-thousands of frame product combinations that potentially have to be included. It is
simply not feasible to simulate every possible combination, and the costs would be staggering.
Both new simulation frame grouping rules and optional default frame categories are essential
to reducing this to a realistic number. New frame grouping rules are needed to reduce the
number of potential product lines when doing simulations. Furthermore, the ability to use
default frame categories with default performance values without simulation is needed to
reduce the number of required simulations, particularly for one-time custom extrusions which
may only be used once.
    I also believe the same approach of comprehensive grouping rules and default categories
could be equally applied to spacer submission.
        Discription for Comment #
Being developed by separate committee - Technical committee

Not consisten with the flow chart. Not editorial and to be resolved
by ballot

Policy issue- NFRC BOD

Persusive and Editorial


                     Resolution of Comment
2



2

2



2
2
2
2
2
2

2

2
2

2&3
2

2
2 - add manufacturer, glazing contractor, suppliers, project
manager.
2




2
2
2
2
2 - see # 26
2
2 - see # C25 & 68
1&2



2



2 - see # C25 & 68
2



2

2 - resolve by providing def. of fenestration




2- Hardware is not modeled



2 - see # C27




2




2
2&3




2 -Note define Expert reviewer



2&3




2&3
2&3




2




2




2

1&2
2

2

1,& 2
2
2
1
2
2,&3



2&3



2 - add manufacturer, glazing contractor, suppliers, project
manager - Gary to review.
2

2

2




2

4,2,1,3,3




2

2
2
2
2




2
2




2

2

2
2
1&2




2&3




2&3




2
2




2

2
2
2
2




2
2
2

2




2

2

2

2

2



2
2
2 - deleted no longer in the document.



2&3

2 & 3 - needs to be after certification section.



2 - comment is incomplete

2
2
2&1




2
2



2

2



2 - comment not clear
2&3




2
3&2



2
2 - Need to discuss
2


2 - see # C147
2

2 - see # C 147

2




1&2
1&2&3
2

2

2



2&3
2&3



2
2
2&3



2




2




2



2
2




2&3
2&3




2 - See #C 147
2
2
2

2
2

2

2 - same as #C178
1&2
2

2

2
2




2
2
2

2
2

2



2 - see # C 48
2
2
2




2
2




2 & 3 - Recognition to be discussed by the BOD

1 & 2 depends on 204 above

2 - This is a good sugesstion more clear.




2
2 - see # C 217




2




2
2
2



2
2 - actual section ref 3.3.1.c
2




2
2
2

2




2



2
2



2




2




2&3
2&3



2
2
2
2

2

2
2




2
2




2
2




2&3

2
2



2

2
2

2- NFRC nonconformance requirements are not defined.
2

2
2
2




2
2



2

2
2



2 - Recommendation the technical committee. See # 265




2 -Good commoent, need to be considered. Comment is that one
can always do cerification again.
2
2

2
2
2

2
2




1 & 2 - Label T.G.
2 - Appendix A is not there. Do we want to include Appendix A or
say to be development
1 & 2 - See # C 285
1&2




2&3
2

2
2



2

2

2

2
2

2 - Confilcts with IA role or obligation
2

2


2&3
2&3
2

2



2



2




2




2

2



2

2&3




2
2



2




2

2



2



2




2

1&2&3

2



2
2




2
2




2




2



1&2
     Commenter Vote on PCP Informational Draft- By Section                                                                                *             Discription for Comment #
                                 CGC = Greg Carney, MKW = Margaret Webb , JS = Joel Smith, DCC = Charlie Curcija, PM =                          Being developed by separate committee - Technical committee
                                 Patrick Muessig, TGR = Tracy Rogers , MF = Marcia Falke, NK =Noel King , TG = Tim Gehling,               1
                                 TDC = Tom Culp, MT = Mike Turner, TK = Tony Kamber, GLC = Gary Curtis                                          Not consisten with the flow chart. Not editorial and to be resolved by
                                                                                                                                          2     ballot

                                                                                                                                          3     Policy issue- NFRC BOD

                                                                                                                                          4     Persusive and Editorial


     CommentorCategory Section                                             Comment                                                       Type                       Resolution of Comment

     GLC 2/23     N/A   1.3      Discussion needs to be held regarding the testing requirement of the Component Based Non-        NP
20                               Residential Product Certification Program.)                                                                    2&3
     JS 4/20      N/A   2.3      A framing system may be granted NFRC approval for inclusion into the Components Library by       NP            2&3
                                 complying with either the procedure of section 2.3.1 or the procedure of section 2.3.2:
                                 2.3.1 Framing system categories with default performance values
                                 A. A framing system may be assigned to the appropriate generic framing system category from
                                 the list below, and use the default performance values associated with that category.
                                 [Placeholder for future list of frame system categories and the associated default performance
                                 values. Alternately, refer to a new technical document, NFRC 304, which contains this
                                 information.]
                                 B. The manufacturer or supplier of the framing system shall provide system assembly drawings
                                 and material specifications to NFRC, along with the recommended frame system category.
                                 C. NFRC shall confirm the appropriate frame system category, and enter the framing system
                                 information into the Approved Components Library.




47
     TDC 5/22    Neg    2.3      Framing System Approval                                                                            NP          2&3
                                 • The ability to use default frame categories and default performance values without simulation is
                                 essential for minimizing complexity, especially for custom extrusions which may only be used
                                 once. Language added to clarify the two options: default categories without simulation, or
                                 detailed simulation by a sim lab. Some argue that this issue should be ignored until the
                                 categories have been developed, but it does affect the PCP process, and it is important enough
                                 to include the framework now.
                                 • Some (but not all) manufacturers have expressed concern about peer-review and the potential
                                 to expose some trade secrets. Use of an IA is acceptable when doing simulations, as long as
                                 the ability to use default categories without simulation is also preserved. On the other hand, an
                                 IA may not even be necessary if an independent sim lab is used.

49
     TK 5/22     Neg    2.3      Deleted entire section and reworded. Added "A framing system may be granted NFRC approval NP                   2&3 See comment # 51 and 52
                                 for inclusion into the Components Library by complying with either the procedure of section 2.3.1
50                               or the procedure of section 2.3.2."
     TK 5/22    Neg   2.3     Added 2.3.1:                                                                                       NP     2&3
                              A. Aframing system may be assigned to the appropriate generic framing system category from
                              the list below, and use the default performance values associated with that category.
                              Placeholder for future list of frame system categories and associated default performance
                              values. Alternately, refer to a new technical document, NFRC 304 which contains this
                              information.
                              B. The manufacturer or supplier of the framing system shall provide system assembly drawings
                              and material specifications to NFR, along with the recommended frame system category.
                              C. NFRC shall confirm the appropriate frame system category, and enter the framing system
                              information into the Approved Components Library.


51
     TK 5/22    Neg   2.3     Added 2.3.2:                                                                                  NP          2&3
                              A. An NFRC accredited simulation laboratory shall calculate the framing system values in
                              accordance with NFRC technical procedures using information submitted by the framing system
                              manufacturer. The information submitted includes, but is not limited to:
                              i system assembly drawings/shop drawings
                              ii system die drawings
                              iii glazing bite
                              iv bill of materials
                              B. The NFRC accredited simulation laboratory shall create framing system models using NFRC-
                              approved software tools
                              C. Multiple framing systems may be subject to frame grouping rules where the grouped products
                              shall use the performance values of the simulated frame group leader.
                              Placeholder for future frame grouping rules. Alternately, refer to a new technical document,
                              NFRC 304 which contains this information.
                              D. The NFRC accredited simulation laboratory shall submit a report to the NFRC licensed IA
                              chosen by the framing system manufacturer in accordance with the NFRC LAP.
                              E. The NFRC licensed IA shall review all submitted information for accuracy and once approved
                              enter the framing system(s) into the Approved Component Library.
52
     DCC 4/20   N/A   5.2     I don’t understand why would specifying authority be responsible for audit costs. I think that audit NP   2,&3
                              costs should be built inot the program cost and charged once through the certificate fee. This
64                            way it increases bureaucracy.
     MT 5/22    Neg   5.2     Auditing expenses should be built into the ACE licensing agreement with NFRC. Random               NP     2&3
                              samplings can be done on their certified projects. The market will not support Sas being
66                            responsible for paying for random audits.
     TDC 5/22   Neg   5.2     Expenses                                                                                          NP      3
                              • Because only a fraction are audited, the costs should be spread out through the overall program
                              fees, not borne by the Specifying Authority who happened to get picked.
67
     TDC 5/22   Neg   6.2     Right to Challenge                                                                                 NP     3
                              • Language change that IA not necessary to issue certification. These can be done directly by
71                            ACE.
     TDC 5/22   Neg   1.2.2   Role of Specifying Authority:                                                                    p, NP    4,2,1,3,3
                              • Editorial changes.
                              • SA does not contract IA to issue label certificate, which can be done by ACE.
                              • IA only audits a randomly selected fraction of product ratings, so language changed to reflect
                              that.
                              • Removed language in section 1.2.2.1 about participating in other certification programs “not
                              related to energy performance.” Certifying air leakage under AAMA/WDMA/CSA 101/I.S.2/A440
                              could be considered "energy related" since it is required in IECC and ASHRAE. This language is
                              not really necessary, anyway.
84
      DCC 4/20   N/A   1.2.2.D   I disagree that there is a need for IA for whole product certification. I believe that it is much more NP   2&3
                                 cost-effective and less cumbersome if random selection of whole product certifications/label
                                 certificates are reviewed by IAs on an annual basis, while ACE is allowed to issue label certificate
99                               in real-time from the component library.
      DCC 5/22   ???   1.2.2.D   I disagree that there is a need for IA for whole product certification. I believe that it is much more NP   2&3
                                 cost-effective and less cumbersome if random selection of whole product certifications/label
                                 certificates are reviewed by IAs on an annual basis, while ACE is allowed to issue label certificate
100                              in real-time from the component library]
      TDC 5/22   Neg   1.2.3     Role of component manufacturers                                                                       NP    3
                                 • Added note that any manufacturer may qualify as an ACE, similar to the language in section
104                              1.2.6 for sim labs.
      CGC 5/22   Neg   1.2.3.4   A framing system manufacturer should have the right to simulate framing systems in-house and          NP    2&3
128                              then have the work checked by an accredited simulator.
      CGC 5/31   Neg   1.2.3.4   Added - F. Choose to use only component product databases and simulation tools under the              NP    2 & 3 - needs to be after certification section.
                                 NFRC program for design evaluation without the intent of product or project certification and
129                              labeling.
      TDC 5/22   Neg   1.2.3.4   Role of Framing Manufacturer:                                                                         NP    3
                                 • Also see section 2.3. The ability to use default frame categories and default performance
                                 values without simulation is essential for minimizing complexity, especially for custom extrusions
                                 which may only be used once. Language added to clarify the two options: default categories
                                 without simulation, or detailed simulation by a sim lab. Some argue that this issue should be
                                 ignored until the categories have been developed, but it does affect the PCP process, and it is
                                 important enough to include the framework now.
                                 • Also see section 2.3. Some (but not all) manufacturers have expressed concern about peer-
                                 review and the potential to expose some trade secrets. Use of an IA is acceptable when doing
                                 simulations, as long as the ability to use default categories without simulation is also preserved.
                                 On the other hand, an IA may not even be necessary if an independent sim lab is used.


130
      CGC 5/22   Neg   1.2.4     We question the role of the IA in the whole product certification based on calculations with       NP       2&3
                                 materials from the databases. Once the glass, spacer and framing system(s) have been
                                 documented in the project specifications, a calculation entity combines the specified products and
                                 framing system and calculates the thermal and optical performance values. The cost of having
                                 the IA check to see if the calculation entity used the specified products in the calculation is
                                 unnecessary. We believe the cost and role of the IA can be dramatically reduced by the properly
                                 designed software using glass, spacer grouping and frame grouping opportunities.
143
      TDC 5/22   Neg   1.2.4     Role of IA                                                                                            NP    3&2
                                 • IA only audits a randomly selected fraction of product ratings, so language changed in multiple
145                              places to reflect that.
      MKW 5/22   Neg   1.2.5     (Comment: Need to create requirements for ACE)                                                        NP    1&2&3
                                 This is a substantial issue and will affect the cost-effectiveness and timeliness of the process. I
                                 cannot vote to approve the PCP document in its current form without the development of all
155                              requirements.
      DCC 4/20   N/A   1.2.5.B   This is not necessary. Independence criteria needs to be maintained only to submit component          NP
                                 level data. Manufacturers or any other trained entity should be allowed perform whole product
160                              assembly based on approved components.                                                                      2&3
      DCC 5/22   ???   1.2.5.B   Deleted - This is not necessary. Independence criteria needs to be maintained only to submit    NP          2&3
                                 component level data. Manufacturers or any other trained entity should be allowed perform whole
161                              product assembly based on approved components
      MT 5/22    Neg   1.2.5.C   You should not have to be an ACE to utilize the software for preliminary design purposes.             NP    2&3
                                 Framing manufacturers should be allowed to use the software for their own product lines.
164                              Component Manufacturers should also be allowed to be an ACE.
      DCC 4/20   N/A   1.2.6.B    Accredited simulation laboratory shall be responsible only for certified simulations of components NP
                                  and submission of components to the component database. ACE is responsible for whole
                                  product calculations. This does not preclude accredited simulation laboratories to have ACEs on
170                               staff.                                                                                                   2&3
      DCC 5/22   ???   1.2.6.B    Deleted - component-based .... simulation tools. Added - This is not necessary. Independence    NP       2&3
                                  criteria needs to be maintained only to submit component level data. Manufacturers or any other
                                  trained entity should be allowed perform whole product assembly based on approved
171                               components
      TK 5/22    Neg   3.1.B.ii   deleted - shall be certified by nationally recognized certification agency which is recognized by   NP   2 & 3 - Recognition to be discussed by the BOD
204                               NFRC.
234 CGC 5/31     Neg   3.3.2.A    (COMMENT: See earlier comments regarding the use of the software tool)                              NP   2&3
    TDC 5/22     Neg   4.1.A      Product Certification - Specifying Authority participation                                          NP   2&3
                                  • Removed need to contract IA at start. IA only necessary if randomly selected for audit.
236
      CGC 5/31   Neg   4.1.D      (QUESTION: Why would there be a situation where a system could not be certified using the           NP   2&3
259                               simulation and calculation tools?)
      GLC 2/23   N/A   5.1.A      (Comment: This appears to require the paper review/audit of every project. Discussion during        NP
                                  previous task group meetings cautioned that 100 percent audit of the paper-trail will result in a
                                  massive accumulation of documents that will quickly become unmanageable for the IA’s.
                                  Contractual requirements of the commercial construction process serve as assurance for the
                                  parties involved. A random paper-trail audit of 10 percent of the non-residential would be
288                               reasonable.)                                                                                             2&3
291 MKW 4/6      N/A   6.5.1.F    What is the basis for the non-refundable payment of $1,000.                                         NP   3
    MKW 4/6      N/A   6.6.6      I would support a permanent Appeals Committee. This committee should have balanced                  NP
302                               representation.                                                                                          2&3
303 MKW 4/6      N/A   6.6.6      I would like more discussion on the designation of the appointees.                                  NP   2&3
      MKW 5/22   Neg   Foreward   3rd paragraph-midway: "Accredited Calculation Entity", should be changed to read "Approved      NP       3
                                  Calculation Entity".
                                  This has been an on-going issue in the development of the PCP and is not consistant with the
                                  discussions of the task goup (see Atlanta meeting notes). The rational for haveing an approved
                                  rather than an accredited entity is to allow for manufacturers to perform in-house calculations
                                  providing they have taken the NFRC training on the calculation tool. Accreditation bodies
                                  become a requirement if and when NFRC certification is required.
                                  The Approved Calculation Entity (ACE) is not subject to the current LAP requirements as is the
                                  accredited simulation lab. The current requirements under the LAP would exclude manufacturers
                                  from performing their own in-house calculations for design/bid purposes.
                                  This sentence is inconsistent with Section 1.1, Scope of the Component-Based Fenestration
                                  Product Certification Program, 3rd paragraph, or Section 1.2.1, Item D, "Approved Calculation
                                  Entities ...".


310
      TDC 5/22   Neg   Foreward   Editorial changes.                                                                                  NP   2&3
                                  IA not necessary to review whole-product rating calculation, issue CAR, or issue label certificate.
                                  These can be done directly by ACE.
314                               IA does not audit every product rating, only a prescribed fraction.
      DCC 4/20   N/A   General    No need to have IA involved at the level of whole product certification, other than random checks NP
322                               of issued label certificates.                                                                            3
      DCC 4/20   N/A   General    Allow frame grouping on the component level. This would include definition of default (punitive)  NP
328                               groups.                                                                                                  1&2&3
337 PM 5/22      Neg   General    Manufacturer needs to be capable of being an ACE.                                                 NP     3
339 PM 5/22      Neg   General    Default framing values need to be determined.                                                       NP   1 & 3 for authorization to use defaults
      TDC 5/22   Neg   General   Manufacturers should be allowed to do final whole product certification. Manufacturing             NP    3
                                 companies should also be allowed to be accredited as an Approved Calculation Entity. This
                                 would allow a qualified engineer from the manufacturer to directly perform the final web-based
                                 combined glass+spacer+frame calculation to get a whole product rating, rather than always being
                                 forced to use an accredited simulation lab for such a simple process. Independence can still be
                                 maintained by having final review by an approved Independent Agency (IA), although this is
                                 probably also unnecessary because of the random audit and challenge processes. If the
                                 manufacturer chooses to use an accredited simulation lab to be their ACE and do the final whole-
                                 product calculation, then review by an IA is definitely not required. In either case, at least one
                                 independent body would be reviewing the final rating.

345
      TDC 5/22   Neg   General   Independent Agency review for whole-product calculations is unnecessary. The IA is responsible NP        3 - Policy, Guidance from NFRC - BOD
                                 for auditing a fraction of randomly selected whole-product certificates, and may also be involved
                                 with the submission of component data. There is no need for IA’s to be involved with and review
                                 every whole product calculation, which is simply selecting the appropriate glass, spacer, and
                                 frame from a web-based program. This extra bureaucracy adds extra cost without much value.
346
      TDC 5/22   Neg   General   Only a fraction of whole-product certificates need to be audited with a documentation trail. The    NP   3 - Policy, Guidance from NFRC - BOD
                                 cost and burden will be overwhelming if an audit and document trail is required for every product
                                 certificate. The same objective can be achieved with a much smaller fraction (10%) of randomly
                                 selected products. If the concern is “cheating”, normal contracts within the commercial building
                                 industry already are a much stronger force than IA audits for ensuring the right product is
                                 specified and installed. Also, there is still a challenge process if anybody wants to challenge a
                                 company’s claimed rating.
347
      TDC 5/22   Neg   General   Overall, to be successful, the process needs to be as streamlined as possible to reduce            NP    3 - to be dissused ar BOD
                                 bureaucracy and cost. If we do not, the system will be ignored and problematic for code officials,
                                 manufacturers, and building owners. On the other hand, a streamlined process will encourage
                                 much broader use, which in the end benefits everyone -- NFRC, consumers, code officials,
                                 manufacturers, and building owners.
348
      Commenter Vote on PCP Informational Draft- By Section




      Commentor Category Section
      JS 4/20      N/A   1.1




  4
  5 MF 5/22        Neg   1.1
  8 CGC 5/31       Neg   1.3
      CGC 5/31     Neg   1.3
  9
 16 CGC 5/31       Neg   1.3
 22 MF 5/22        Neg   1.3
 23 MF 5/22        Neg   1.3
 28 MKW 4/6        N/A   1.3
      DCC 4/20     N/A   3.2
 55
      GLC 2/23     N/A   7.0
 73
 74 DCC 5/22       ???   1.1.A
 75 DCC 5/22       ???   1.1.B
      MT 5/22      Neg   1.2.2
 83
      TDC 5/22     Neg   1.2.2




 84
      MKW 4/6      N/A   1.2.2.B




 92
      DCC 5/22     ???   1.2.3.2.B

112
      DCC 5/22     ???   1.2.5.A
158
      TDC 5/22     Neg   1.2.8
173
239 GLC 2/23       N/A   4.1.A.F
      CGC 5/22   Neg   4.1.C



249
      CGC 5/31   Neg   4.1.C
251
256 MF 5/22      Neg   4.1.C
    TDC 5/22     Neg   6.1.3
290
312 MT 5/22      Neg   Foreward
      DCC 4/20   N/A   General

329
Vote on PCP Informational Draft- By Section                                                                     *
       CGC = Greg Carney, MKW = Margaret Webb , JS = Joel Smith, DCC = Charlie Curcija,           PM
       = Patrick Muessig, TGR = Tracy Rogers , MF = Marcia Falke, NK =Noel King , TG = Tim                      1
       Gehling, TDC = Tom Culp, MT = Mike Turner, TK = Tony Kamber, GLC = Gary Curtis
                                                                                                                2
                                                                                                                3
                                                                                                                4
                                                 Comment                                                     Type
       {{Terminology includes Components-Based Fenestration Product Certification Program,    Editorial
       Components-Based Non-Residential Product Certification Program, Components-Based Whole
       Product Certification Program, and Components-Based Fenestration Product Program. This
       needs to be standardized according to the input from the committee.}}

       3rd paaragraph - product certification AUTHORIZATION under ….                                    Editorial
       Commercial Fenestration systems - added sloped glazing systems                                   P
       Fenestration - : (COMMENT: The official NFRC definition should be provided in this               P
       document!)
       Deleted - Simulation                                                                             P
       Need to add EXPERT REVIEWER.                                                                     P
       Lineal Supplier:: Remove one colon.                                                              p
       {peer review} Should there be a definition for Expert Review as well?                            p
       ACE only needs to know how to use NRFEN, not other NFRC-approved software tools, like            P
       THERM or WINDOW.
       (Comment: This section needs to be rewritten to fit the component based program and the          p
       Role of the Design Professional .)
       Added system                                                                                     p
       Added assembly                                                                                   p
       3rd paragraph - "… and NFRC-licensioned fenestration Specifying Authority" Remove the word p
       fenestration.
       Role of Specifying Authority:                                                                    p, NP
       • Editorial changes.
       • SA does not contract IA to issue label certificate, which can be done by ACE.
       • IA only audits a randomly selected fraction of product ratings, so language changed to reflect
       that.
       • Removed language in section 1.2.2.1 about participating in other certification programs “not
       related to energy performance.” Certifying air leakage under AAMA/WDMA/CSA
       101/I.S.2/A440 could be considered "energy related" since it is required in IECC and ASHRAE.
       This language is not really necessary, anyway.

       Entity (let’s be consistent. There’s a number of different terms in this document…Approved        p
       Calculation Entity, Calculation Entity, Approved Calculation Entity, Approved Calculation Entity,
       Calculation Entity. Let’s pick something and use it throughout the document otherwise it will be
       open to mis-interpretation and could lead to confusion to the reader);

       Revised to read - Note: the spacer information excludes sealants. Appropriate sealants are       p
       specified during the IGU component definition using approved NFRC software tool.

       Added - software tool, which incorporates Component- Modeling Approach (CMA) and full            p
       database solution, further called NRFEN
       Liability disclaimer                                                                             p
       • Editorial change
       This procedure needs to be discussed…what do we require in the current program?                  p
Paragraph C reads "The IA shall seek approval of NFRC prior to converting the Documentation p
trail document to electronic storage." We believe the most efficient means of the Document
trail submittal and retention will be electronically. We strongly recommend that electronic
submittal and storage be allowed.
Deleted - The IA shall seek approval of NFRC prior to converting the Documentation trail      p
documentation to electronic storage.
Last sentence - currently everything can be electronic.                                       p
NFRC Administrative Action                                                                    p
• Corrected wrong section reference.
"accredited calculation entity" should read approved calculation entity.                      p
Streamlining of mandatory documentation and removal of the requirement to keep paper-trail.   p
This is 21st century, let's save the trees and reduce the burden when technology allows for
that.
        Discription for Comment #
Being developed by separate committee - Technical committee

Not consisten with the flow chart. Not editorial and to be resolved
by ballot

Policy issue- NFRC BOD

Persusive and Editorial


                   Resolution of Comment




4
4
4
4 - Defination from NFRC Glosarry

4
4 - Need to develpe an definition
4
4 - see #C22
4 - add 'appticable' before approved.

4 - see 72

4
4
4 - delete fenestration consistent terminolagy

4,2,1,3,3




4




4



4 -add 'applicable NFRC approved software and …

4

4 Already done
4- Add 'hard copy or electronically for storage'




4 - See # C 249

4 - See # C 249
4

4



4 - See # C 249

				
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Description: Ace Agreement document sample