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/
