FenCan declined to comment on the controversy over whether to use U-value or ER as the performance metric, citing disagreement within the membership. It did recommend that both values appear on any labelling regime, regardless of which is chosen as the metric.
In the response, FenCan expresses its concern that any federal regulation needs to align with provincial codes, laws and regulations or else risk setting up barriers to trade in window and door products across provincial borders and internationally. Any federal regulation can only apply to goods shipped across provincial boundaries. A policy that establishes different regulations than provincial regulations risks favouring or penalizing companies that ship interprovincially relative to their competitors who deliver only within their province.
FenCan points out that the final stage outlined in the Roadmap, Tier 3, calliing for 0.8 U-value/ER40 performance by 2030, is not achieveable with proven technology. At present, such a high level of energy performance would likely only be possible with triple-paned insulating glass units with low-E coatings on three surfaces, presenting significant concerns about esthetics, installation, shipping, durability and price point. For skylights and sliding glass doors, even Tier 2 proposed standards may be unachievable or at best impractical.
“Fenestration Canada has collaborated with member representatives and its technical consultant to respond to NRCan’s national regulation discussion paper in an effort to ensure its technical viability for window and door fabricators," said Jennifer Small of Screenco, FenCan president. "FenCan is a leading resource for NRCan and we need to ensure the manufacturing feasibility of window and door products in the future. We encourage member companies to submit their additional comments directly to NRCan and Fenestration Canada by the newly extended deadline."
Read the full FenCan response
Read the discussion paper
Read the full Roadmap