In response to my previous post about the impending changes to affect the WER scheme, Giles Willson from the BFRC agreed to answer a few questions I put to him as follows:
Can you explain how the impending changes to the compliance with building regulations in October will affect the industry as a whole?
We will not know what the actual requirements for the revision to Approved Document L Conservation of fuel and power & Approved Document F Ventilation until they are published at the beginning of April 2010.
We know from the 2009 consultations that for England and Wales the proposal is WER band C for replacement windows and U value 1.8 for replacement doors. Regarding trickle ventilators within replacement windows these are going to be considered mandatory for all replacements. In addition conservatories are being considered to have the dispensation for compliance under ADL removed; this would mean conservatories would need to meet a thermal performance standard.
Therefore if you supply or fit replacement windows, doors or conservatories you will be effected; the actual details will be known in April – so watch this space.
There seems to be a lot of concern about the real value of solar gain in WER calculations. Wouldn’t we be better just setting tougher U Value requirements as part of the scheme?
The WER calculation takes into account the following:
Whole window U value
Solar gain
Air leakage
We all know that solar gain does make a difference to a building; the averaged constant used by the BFRC method simplifies the situation. Do you really want different window ratings for a North, South, East or West elevation, let alone a North, North East window?
The whole window U value is an element of the BFRC equation, it is important but WER’s reflects the solar gain aspect – a unique feature of glass compared to most other products used on the exterior elevation of homes.
Personally, I’m concerned that having WER’s as the only way of complying with building regulations will stifle innovation, choice and creates problems should any company in the supply chain cease trading. For example, what will an installer do if the company they purchase sealed units from ceases trading? Surely there needs to be a quick way for installers and fabricators to switch to an equivalent product from an equivalent supplier?
The WER Licence specifies the components used in a window; if these are no longer available the approved window is not a viable option, however the question did state that if your unit maker ceases trading what do you do. In these cases another unit maker, who can manufacture to the original specification (exact components etc.) can be used.
Regarding innovation; different components can be modelled within a simulation to check the overall effect on the rating – this is a very cost effective solution therefore we could argue we assist innovation.
I understand there are currently around 300 companies in the UK with an energy rating, but FENSA claim to have over 9000 companies in their scheme. Can the simulators simulate, the IA’s audit and the BFRC register the rest of the industry by October?
The number of companies stated are correct however, we do need to think about the supply chain. Many FENSA installers only undertake a few jobs, they use windows which have been bought in; these installers will buy in a window which is WER registered and install this as compliant with regulations.
You also have companies who fabricate and install – these companies need to get their own Licence or be part of the Authorised Retailer Scheme.
The authorised retailer scheme; this enables companies to use their frame supplier licence and either source their own units or buy from the frame supplier, and have their own BFRC WER Licence.
Therefore the number of additional Licences will increase if WER band C is made mandatory however, not all 9000 FENSA Registered businesses will require their own Licences.
Do you think that these proposed changes will ultimately force many smaller sealed unit manufacturers, PVC-U fabricators and installers out of business?
We do not believe that it is the Governments intention that any company goes out of business due to regulatory changes. However, regardless if the Building Regulations require WER or whole window U values these would need to be calculated for every combination of glass, unit and frame.
With the more demanding specifications, products do require verification; therefore companies who have undertaken the preparation and have data on their products should survive. Companies who have not undertaken a simulation or have data on the whole window U value or WER will be disadvantaged and could result in their failure.
For more information about the BFRC visit http://www.bfrc.org/
Tags: Approved Document F Ventilation, Approved Document L Conservation of Fuel and Power, BFRC, bfrc authorised retailer scheme, Giles wilson, u values for doors
I think this is a great attitude to take i cant wait until it comes in, this will hopefully get rid of a lot of so called company’s or fitters that think they know what they are doing but really they are destroying our business by selling sub standard products at a cheaper cost.
I agree with Graham, it will get rid of all the half-baked attempts at companies out there. But Giles Wilson sounds like he is ready to plough ahead with the changes. It sounds like he doesn’t really care about those who haven’t made the change to WER’s. But he doesn’t have to, and those companies who haven’t have had plenty of warning, so they wouldn’t be able to blame anyone but themselves.
The issue with trickle vents is an absoltue joke. They are going to push trickle vents onto companies and customers, both of which don’t see the need for them! I don’t see any valuable advantage of drilling a hole through an ‘A’ rated window. The argument for trickle vents is that they provide useful background ventialtion. But how useful are they when 99% of people keep them closed anyway? And no matter how much education you give to the customer, they will always keep them shut because they will open a window if they want ventilation and they won’t want noise to travel through them, making it difficult to sleep if they live near a motorway. TV’s are an unwanted waste of time and material. We could do the environment a favour and not use them!
Mr Willson should get a job as a politician , but I suppose he has had 6 years to learn the schpiel he needs to avoid answering questions .
Graham and DGB , I think you would find a tighter spec on U values alone would close a lot of the smaller unit makers as hardcoat like K would be regulated out and the small boys can’t handle soft coat and cannot invest in the necessary kit . So if they now buy low iron / K low iron they are still in business on a technicality , the technicality being an exagerrated solar gain that keeps a poor insulator like K in the frame , so to speak.
Point well made about U values, what about trickle vents?
Giles …..[ We all know that solar gain does make a difference to a building ]
Yes but how and how much? UV fades furnishings and low iron lets 66% more UV in ?
The sun can also overheat your property in the summer ,resulting in fans and aircon!
Giles …..[ the averaged constant used by the BFRC method simplifies the situation]
No, the averaged constant is baloney, Where does the meteorology reference data that he uses in the formula come from ? The ridiculous amount used in the formula is nonsense and does nothing but confuse the situation!
Giles …..[ Do you really want different window ratings for a North, South, East or West elevation, let alone a North, North East window? ]
Some might argue that it would be quite clever to be able to specify products for customers requirements , orientation being included in the considerations . Does Mrs Jones really want low iron glass glaring and excessive UV on her south facing 3mtr patio door? Or does she want a tinted glass for the shading combined with a good 1.1 U value in one unit ? Well, unfortunately Mr Willson and his ilk are trying to take that decision from you, tinted glass won’t comply! Are our industry professionals being regulated to prevent us giving our customers the most appropriate products?
Giles……[ WER’s reflects the solar gain aspect]
No they don’t , they exaggerate it .
Giles ….[ We do not believe that it is the Governments intention that any company goes out of business due to regulatory changes]
What have the Government got to do with this? This is a GGF/ BFRC concoction which they have undoubtedly been lobbying very hard to get written into the regs , the government input involved a previous incarnation of the formula by Robin Kent . The present formula seems to have a much higher solar factor, which is pure GGF/BFRC , If the government wanted to save heating costs it would specify U values, not create such a hair brained scheme , which by the way the CLG have not even bothered to scrutinize!
Giles …….[regardless if the Building Regulations require WER or whole window U values these would need to be calculated for every combination of glass, unit and frame.]
The WER scheme has of course an extra variable or two, the manufacturer and the installer ( the bits that need paying for).
Whole window U values need calculating only for items with differing values , an identical spec of a unit would have the same value whoever made it , and at least whole window U- values would be an accurate reflection of the energy saving ability of the window, and I really think it is daft that each obscure glass having different solar characteristics should really have it’s own rating certificate, just to prove bathroom windows comply.
Mr Willson , I am sure that you will pop in to see how the interview was received, so I would ask a couple of questions if I may , firstly ( tongue in cheek ) have you identified whether your scheme is a energy efficiency tool or a marketing tool, have you told A rated certificate holders that they cannot claim their windows gain more heat than they lose , or can they?
Secondly , would you be so kind as to show any evidence of the reference source for the calculation of the solar gain constant in your formula? Can you point to a publication or factual recorded measurements that would form the basis of this solar constant?
I won’t hold my breath on this one, as I have been asking the question of you for about 12months and still have seen no evidence to show the legitimacy of the formula.
DGB , compulsory Trickle vents , absolutely stupid a ridiculous idea , but in fairness to the GGF I seem to recall that they were not to keen on this one either and made the point in the PartL consultation process, something I missed as I was so focused on the daft WER scheme.
Kevin Ahern
PS thanks for the interview Matthew , I hope you don’t mind my skepticism on this issue
Kevin – I’m quite sure that when Giles agreed to this interview, he was aware that you would comment.
On the one hand I understand the need for a simplified formula which consumers can understand, but on the other hand, if the science behind the scheme doesn’t actually stack up, then I’m sure every one in the industry would share your concerns.
In the end, we need a scheme that the industry supports and believes in, and clearly at the moment judging by comments on this website, the Thermoseal blog, and others, there does seem to be a degree of support, but by no means unanimous support.
Kev – you seem to be the most vocal critic. Maybe you and Giles should sit down and talk this through (with me filming).
Matthew
All I want to see is the reference source for the solar gain claims, simple as that really , I can then find out how it was averaged and if the maths stack up, which I am sure they don’t .
Even on the BFRC calculation report, the notes say that the figures are obtained from climate data for Aberdeen, Manchester and Plymouth, and then go on to claim that Aberdeen has a higher solar flux than Plymouth.
As part of my research I even looked at BS EN 410 , this is the maths that they use to calculate UV, Light and solar transmittance values , and guess what, I have a hunch that there are issues in there too . My maths are not quite up to proving it yet , but a little more time .
My angle on this is simple, I try to tell my customers the truth , unfortunately the I believe that the WER scheme compromises that . I honestly don’t believe many in the industry give a damn if it is right or not, or would even consider questioning it. They will get a certificate when they have to, and consider it another cost of sales and see how it goes .
I never saw myself as a Jeremy Paxman before Hmmm…..interesting
I was also thinking the other day that I have seen a number of technical managers from the systems companies having some reservations, but seemingly not being able to voice them as they may compromise their own position , bearing in mind a lot of the systems companies have paid for the rights to be certified simulators of the scheme.
I would assume that internal company politics has a big part to play in what some of our industry technical boys and girls feel they can say out loud and in print. These are the people who should be shouting ,but unfortunately are wrapped up in the whole sorry process of putting a higher number on the certificates.
I have a reasonably sound technical background and have no superiors to answer to, so I can ask my questions and show my concern openly.
Granted, when I first contacted you I was not sure how my rantings would be received but I have been encouraged by some of the responses and some calls I have had , hence my confidence to be more ‘vocal’ on the topic .
Matthew
It is a strange one this, but I am intrigued by Giles’ interview with you. If he was aware of my presence on your blog he would be expecting my comments and questions ,fine , but does that mean that he intends answering them on this blog?
Fair play Matthew, I suppose you now have an open line into the BFRC, as if they new what to expect before they agreed to your interview, they can hardly ignore the blog afterwards.
Time will tell I suppose , anyway , there is always ECo build, I’ll have to keep some powder dry for that one
Kevin – there is no arrangement in place for Giles to respond to your queries, or anybody else’s, although it would be nice if he did.
I certainly don’t have an open line to the BFRC, but am very grateful to Giles in responding to the questions I sent him very swiftly. Thanks.
Ah, I understand now , I thought the interview was a little more formal than what appears to be the case , sorry about that .
Hi Kevin,
Obviously you are free to air your opinions in whatever way you see fit, I’m just curious as to what you are trying to achieve?
The scheme is there to provide a method for comparing window performance which is audited to ensure components within the window are used in line with the systems company/manufacturers guidelines and comply to the required standards.
If you are going to move from criticising the BFRC scheme to trying to pick holes in European Standards, good luck to you!!!!!!
Hi Philip
Philip ……[Obviously you are free to air your opinions in whatever way you see fit, I’m just curious as to what you are trying to achieve?]
Sometimes I ask myself why I bother, as I seem to be banging on and only a few people get it. I suppose that sometimes you get to a point that you say enough is enough. Like many I had given the issue sparse attention until I realized the potential of having this scheme as the proposed only method of compliance to the building regs. As a standard product I supply SGG ultra N which has std centre pane U of 1.3 ( 1.1 argon filled ) and I was being told that a Pilk K unit of 1.6 U value gave a better window energy rating. After a fair bit of research I found out why , the ridiculously exaggerated solar claim portion of the formula. The reasons behind this figure I believe are commercial and not energy rated. So what am I trying to achieve , well I suppose I would like the industry to see exactly what a fudge the scheme is , when the industry understands it then it can decide what it wants to do with it. I believe that the consumer is being misled with this rating system and that cannot be good. On a theoretical note, the fuel saving advantage of purchasing an A over a C rated window can be as little as £13 a year for standard semi. A rating scheme that has that little difference, considering the initial added purchase costs is ridiculous. I want the lie of windows supposedly providing more heat than they lose to be exposed as just that, a lie.
This scheme has not appeared in the building regulations by accident , I guess things like this have to be lobbied hard to be included, and with a wink and a nod hey ho ,my purchasing decisions ,my customer advice and my product offer has been effectively limited and changed by a scheme that is not based on science and not vetted by the CLG.
I would like to see the industry wake up to this fact.
Does it matter? Well I guess that is a decision that the industry will have to decide on before someone else decides it for them ..that double glazing is a con.
It matters to me !
Philip …….. [The scheme is there to provide a method for comparing window performance which is audited to ensure components within the window are used in line with the systems company/manufacturers guidelines and comply to the required standards.]
Bingo , the big issue , the scheme does not actually measure the windows energy performance , the BFRC guidance notes will tell you that. So how can it compare what it doesn’t even measure !!
Philip ……[ If you are going to move from criticising the BFRC scheme to trying to pick holes in European Standards, good luck to you!!!!!!]
What you have to think of in this regard is that these standards are written by industry, for industry , the consumer has no input or influence and there is no independent authority that sits on the BS committees that do the work , who polices that?
Were you ever in the position of trying to explain to a customer that the scratch in his DG unit was fine because you can’t see it from 2.5mtrs in flat light , whilst facing the other way at midnight ? well I’m sure a lot of the standards claimed in some installers advertising aren’t exactly written to help the consumer !!
Solar energy or gain is a buzz word at the moment , but there is not a great deal known within our industry about it , in the USA there is a body called ASHRAE ….American Society of Heating, Refrigeration and Air-conditioning Engineers , they take the issue of solar gain seriously and factually, after using a solar calculator based on their measurements you can soon see how exaggerated the claims by the BFRC are.
I have been told that the formula is a government secret, I have been told that the issue does not concern me and I have been told that I should not be questioning the scientists who know best on this issue ….all by BFRC representatives , talk about red rag to a bull .
That is why I have one simple question that I need an answer to …. where is the climate data that the BFRC used to work out the 218.6 number
Kevin
Picture the scene
Sunday lunch time in the Ahern household.
Mrs Ahern: What a lovely morning Kevin! Its so nice to feel that lovely sunshine coming through our window,dont you think?
Kevin: (in an raised voice) DON’T YOU MEAN UNSUBSTANTIATED SOLAR GAIN.
Mrs Ahern: Errr…….
Kevin: ( in an loud voice) THATS JUST THE TYPE OF TOSH THAT GILES WILLSON WANTS YOU TO SPOUT!!
Mrs Ahern: Darling why is it every time I mention window or sunshine you become very irate?
Kevin: (shouting as loud as he can) THATS BECAUSE I SPEND ALL WEEK CHALLENGING THOSE BL***Y IMCOMPETENT IDIOTS AT THE BFRC WITH ALL THEIR FALSE DATA ON SOLAR GAIN AND STILL NO ONE TAKES A BLIND BIT OF NOTICE!!!!!
Mrs Ahern: (trying desperately to defuse the situation) I know, lets both go and sit in the north facing room, you know the one which is shaded by that lovely big tree……it often feels much cooler there……… perhaps you’ll feel more comfortable……
Kevin (incandesant with rage by now) ARE YOU TAKING THE MICKY?
Mrs Ahern: Errrrrrrrrr More tea darling……….
I Daren’t raise my voice to my Mrs ,………. but apart from that , pretty accurate
Very good
I guess your getting tired of my rantings, but 1 more for now unless someone asks a question
G Factor —-what is it? If I said G spot it may get more attention, but alas
As EN 410
Put very simply, the calculations of the transmission properties of glass are done across the wavelengths of the solar spectrum with the properties in question.
Therefore..
UV transmission , reflection and absorbtion properties are measured over the wavelengths 280-380 nanometers ie the UV band of the solar spectrum, easy.
The light transmission and reflection properties are measured over the wavelengths 380 -780 nanometers ie the visible light band of the solar spectrum , easy.
The next bit would follow that the energy properties should be measured over the wavelengths 780 – 2500 nanometers ie the near Infra Red heat energy bands , well there is a calculation for this but it does not give us our G value .
Odd really but the G value is calculated over the entire UV- Near IR spectrum ie 300-2500 nanometers !!
Why is this ? I don’t know, but if anyone out there does please shout up.
We know that low iron, for instance gives high G values but, as it also gives high UV and Light transmission values, it is hardly surprising that the G value is being helped upwards, this is odd when the UV and light do not actually contribute to any heat gain at all. In fact Pilks Optiwhite K units actually reflect 2% more Near Infra-Red ( actual solar gain) back to the atmosphere than normal annealed K units.
If we look at a Pilk K optiwhite unit , the energy transmission in the IR range is only 71%
but the G value is given as 0.79 ( 79%), It would appear that the theoretical solar gain through glazing is exaggerated by over 10% in this and other examples.
With an actual Infra Red (solar gain), energy transmission rating used as the G factor, and a realistic solar flux figure added into the mix , include a little window shading and I think you can write off solar gain as a realistic heating influence through glazing in most of the existing UK housing stock.
I would like to add some information regarding the issue with trickle vents. Trickle vents provide as you say background ventilation, the newbuild properties need this added ventilation to keep the house and its occupents healthy the tighter you make the house the more VOCs, moisture, dust mites you seal in to the property, making your nice new property nice and damp just what mold needs. With regards to the issue of trickle vents next to motorways and causing excesive noise, you should be fitting Acoustic Ventiltion not standard slot vents in theses situations. This is the sort of eductaion the general public need and they do not seem to get it from Some (not all) window fabricators / Installers.
THATS BECAUSE I SPEND ALL WEEK CHALLENGING THOSE BL***Y IMCOMPETENT IDIOTS AT THE BFRC WITH ALL THEIR FALSE DATA ON SOLAR GAIN AND STILL NO ONE TAKES A BLIND BIT OF NOTICE!!!!!
I think you’ll find it’s incompetent, (an adjective, not competent; lacking qualification or ability; incapable).
As an “incompetent bfrc idiot” I find your comments somewhat offensive, discourtious and generally unhelpful.
Its clear you have much time to write on blog sites about your quest for specific answers on solar gain. Unfortunately there are those who give their time freely to industry bodies, in an attempt to assist them with difficult decisions on behalf of the industry (at least that bit that wants to improve the standards within it).
Industry had a choice, develop a uniform scheme that consumers understand or go down the SAP route, caculating every window, in every location, in every building.
Dont slate the bfrc for collating some data that is slightly different in some locations or orientations. A simplified scheme enables consumers to understand simple measagges, A is better than B, B is better than C etc.
I doubt WER’s will be the sole method of compliance, but it does simplify compliance for the industry and those it serves, our customers.
Lets see what the government decides once its read all the replies before commenting further, as there isn’t sufficient time to write a reply to every previous comment.
Alan Burgess
masterframe windows ltd
BFRC License holder No1,2,3,4 & 5 + a dozen or so others
Alan ,
I am not 100% sure on this, but I think you are aiming this one at me, however I think you will find that it was Ian who made the comments to which you take offense, in what I read, as a humorous mickey take at my ‘obsession’ to the cause.
I make time to comment on blogs such as this precisely because I absolutely believe that in truth A is not necessarily better than B is not necessarily better than C.
I respect that a lot of people put a lot of time into industry bodies to help with making difficult decisions , but that does not mean schemes and decisions cannot be challenged on the on their own merits.
Windows are a nett heat loss element of a building and should be judged (for existing housing stock) purely on this measure ie overall window Uvalues. You cannot alter the orientation of a window to benefit from solar gain, just as you should not exagerrate the quantity of solar gain to pretend that they do.
I have NEVER slated the BFRC for the data collection I have purely questioned it’s origin, and am still to get a scientific response, so I will continue to question. I expect data to be different in locations and orientations but cannot identify the climate data used and question the idea of averaging for an average orientation
The scheme is full of holes because I believe it is fundamentally not correct and cannot answer it’s critics because of this.
I do hope you understand that I have never deliberately been discourteous, generally unhelpful or even offensive , and if I have I apologise , but I think your remarks on that score should be redirected toward Ian’s sense of humour.
If you would wish to address the WER issue then I am all ears .
Kevin Ahern
No licenses until I have to , thanks all the same .
Apologies if the quote(s) was misguided……
As I said, I doubt it’ll be the ONLY method of compliance so I am sure those that dont accept, dislike or distrust bfrc WER’s, will be able to find an alternative.
I’ll prefer to wait until CLG decide whats actually happening, (now they’ve consulted everyone) rather than publically debate something, that may not happen.
NO I dont have inside information, but CLG have been known to change their minds before………best we wait and see, then discuss further!
Alan Burgess
Thanks for clearing that one up Alan.
However I am not sure what the CLG have got to do with this, WER have happened, you appear to have spent a small fortune on them.
I too believe alternative compliance arrangements will be made, they have no choice, as otherwise all obscure glasses would need there own certificates.
My issue is with the WER scheme and the claims people are making with it . I don’t think it at all problematical debating a window energy rating scheme that by the BFRC own admission does not actually measure the energy flow through a window .
Answer 1 question,
PVCu casement window U value 1.8 Rated C
PVCu casement window U value 1.6 Rated D
which one is currently better for a houseful of windows ?
I know which ones I would fit to my house but would Mr & Mrs Jones?
Kevin
Kevin
Whoops!
Many ,many apologies that my gentle leg pull at your expense appears to have caused unexpected collateral damage.
I feel a bit like that Gavrilo Princip, who was idlely shooting sparrows in his Sarajevo backyard at the same time as Archduke Franz Ferdinand’s car happened to be driving past!
I am slightly baffled how what was clearly a micky take could be so misconscrewed (memo to self -must check spellings)
Seriously, do keep up your dogged lobbying, its hard not too agree with your logic on several points.
As i have been housebound for 3 weeks due to doctors orders I have through boredom ended up reading all sorts of articles relating to the BFRC/WER.
Kevin – I think we are peas in a pod mate!
I have studied solar gain and what if any others use around Europe.
Ask my mate at Strathclyde Glass if he thinks his solar gain is better than Barcelona?
I have been asking all these questions you raise over the past two years – if it’s crystal clear data why don’t they publish how it was finalised?
In Germany the highest standard for energy conservationin a home is the Pasiv house standard- here solar gain has to be balanced. Iam sure most people open their windows when solar gain is highest or turn on the air con!
Did anyone get a set of rules yet for the WER scheme?
m
I hope that what you have got is not catching, as If I am that close in a pod with you I may get it
I do happen to know the rules for the scheme however.
Turn round , drop your trousers, touch your toes and smile !!
Then get your cheque book out to pay for the shafting they gave you
All in good fun