GGF analyses Government views on Building Regulations in 2010 and 2013

Time never stands still and already moves are being made by the Government to look at what Building Regulations (Approved Document L) will look like in 2010 and 2013. The GGF were asked to respond to these views after working with the CLG and its predecessors effectively for many years.

The GGF advocated a practical and achieveable approach and appreciated that although the discussion document was specifically directed towards new dwellings felt there was likely to be a roll out to replacement windows as well, and indicated that it would cover both areas in its comments. Chief Executive Nigel Rees’s letter to Shona Dunn at CLG continued:

'Our Industry showed in 2002, that it was more than willing to work with Government to reduce carbon emissions and the wastage of energy in new build and replacement windows. We have recently undertaken a major environmental study which clearly shows the immense value to reducing carbon emissions, by the installation of energy efficient windows.

As we have seen in the 2006 version of Approved Document L, we now have a route to compliance, through Window Energy Rating (WERs), administered by the British Fenestration Ratings Council (BFRC). We would wish to see greater reliance on WERs and less reliance on U values. As has been clearly discussed in the past, U values are limited merely to energy loss and do not encompass solar gain, which WERs are able to do. Certainly, when considering the building as a whole, there is a need to also consider channeling energy into the building and the lighting impact rather than merely that energy leaving it.

Since the GGF, took over the administration of BFRC we have seen a huge increase in the number of windows being rated and although any window rated A-E is compliant in England and Wales, for the purposes of replacement, we are seeing the majority in the A-C bracket. The current statistics being (percentage is of total):

Category A: 98 (17%)
Category B: 151 (27%)
Category C: 225 (40%)
Category D: 54 (9%)
Category E: 42 (7%)

A total of 570 windows from 112 companies

However it should be clearly understood that neither the number nor the proportions of energy efficient window types registered by rating band should be seen as representative of numbers of windows actually produced and installed at this stage. We are working with the Energy Saving Trust and FENSA to try to generate a reliable means to monitor numbers and rating band for replacement windows actually installed. Our best guess prior to this being available is that the proportion of A windows actually installed is insignificant and in a recent EST survey the number of A, B or C rated windows being installed was less than 3%.

Furthermore at present there is neither the investment nor the capability of producing 100% of windows installed as even C band, let alone more demanding specifications. This emphasises in our view that levels of improvement need to be not only realistic, but also that adequate lead-time needs to be part of the process.

The Industry is ready to work with Government, to see continual reductions in emissions from dwellings to meet the necessary targets. The first step from 2010 (subject to sufficient notice) should be to make a compliant replacement window, one which carries a WER of ‘C’ as a minimum.

Any form of prescriptive description of windows, concerning framing material, number of panes of glass or other elements should be avoided and merely the performance required for the particular window stated. Suggesting either triple glazing or warm edge technology is not supported as it is too prescriptive on Industry. Industry seeks direction from Government by way of a “target” to be achieved. How that target is achieved should be left to the Industry to use their technological know how. As previously stated, the Industry wants to work with Government to meet the emission targets going forward. To do this though, the Industry must be able to function economically. We are currently seeing a decline in consumer interest in replacing their windows. Obviously moves that would greatly increase the cost of Energy Efficient Windows, if perceived as unaffordable by the consumer, would slow down the introduction of this important energy saving product further.

In summary, we support the Government’s drive towards lower carbon homes and the glass and window industry are ready to play its part. We have reservations about the over prescriptive signals being sent out in Table 2 and the reliance on U values. Solar gain is an important benefit of windows and is only considered within WERs and comprehensive SAP models. We believe stricter ratings should be the target, first moving from E rated windows to C rated versions and then further increases later. However we emphasise the need for sufficient lead-time as, though the technology obviously exists for A band windows, the capacity and investment for the necessary volume of production for Band C and particularly higher levels is not yet in place.'

The GGF looks forward to working with the CLG to discuss practical solutions for a way forward. Should you want to get involved in the discussions please contact Giles Willson gwillson@ggf.org.uk.