Report from the Fabricators Council - What do we think of the Roadmap?
Brad Fevold, chair of the Fenestration Canada Fabricators Council, went into the meeting with a tight agenda based on the feedback from the American Architectural Manufacturers Association A440.2 ballot on window energy standards. He knew the feedback would be a good basis for discussion after seeing the comments on Natural Resources Canada's Roadmap laying out the federal government's plans to promote higher-performing windows across the country in the years ahead. He used a few slides from NRCan's presentation of the feedback and took the group through them to see if fabricators were aligned with the rest of the industry stakeholders who responded.
"We came out of the meeting with some pretty good understanding of whether we think we can support what could happen," he says. "We had four or five actions to the board on some things we still need strong clarification on, like enforcement, early timing, the additional burden on administration and concerns about any misalignment between the federal mandates and the provincial building codes. That was a real concern, we really think they should be aligned. There was a real desire to have some performance paths in there like where B.C. has gone."
Fevold says fabricators are concerned with an approach that mandates every fenestration product meeting a certain energy standard, when the same or even better energy efficiency might be achieved by having lower-performing products in one part of a building and higher-performing products in another. For instance a homeowner who wants lower-performing operating windows in one part of the house, but is fine with very high-performing fixed windows in another, may be forced instead to accept middle-of-the-road performance throughout in order to have everything come in under the standard.
There was a general feeling that NRCan was hearing and accepting fabricator feedback and incorporating it into its decision-making process, Fevold reported.
The tight agenda prevented the group from getting into any proposals for how to enforce energy standards, but the issue is an important one. "There's always a concern that if you enforce a federal mandate on everyone the responsible companies are going to comply and you don't know if others are complying," Fevold explains. "Because of the way federal mandates work, in theory you don't have to comply with federal mandates when you build and sell the products inside the province."
In general, Fevold says the fabricators felt the next tier in NRCan's energy performance targets is achievable, but the next two tiers are too stringent to meet in the suggested timelines. The good news is NRCan seems to have heard the feedback and included it accurately in its reporting.
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