Glass and Glazing Federation response to the OFGEM consultation on the Energy Company Obligation (ECO) : Guidance for suppliers.

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1 Glass and Glazing Federation response to the OFGEM consultation on the Energy Company Obligation (ECO) : Guidance for suppliers. The Glass and Glazing Federation is a major Trade Federation representing the fenestration industry supply chain and is particularly interested in the replacement window sector and the impact of ECO. We are pleased to offer any additional support and advice which OFGEM may find useful to assist with the successful implementation of ECO by contacting us at the following address: The Glass and Glazing Federation 54 Ayres Street London SE1 1EU Contacts: Giles Willson Deputy Chief Executive and Director for Technical Affairs / Brian Smith Home Improvements Manager / Background to ECO The GGF do not agree with the open letter Information on determining savings for qualifying actions regarding the carbon savings proposed to be recognised. We believe the actual energy and carbon savings for replacing the window should be taken into consideration and not just any additional savings to the current building regulation requirement for replacement windows. We do not understand the logic behind this proposal, as detailed within our response to Q4 the majority of carbon and energy savings are from the original window to the current building regulation standard window. Q1 no comment Q2 no comment Under Article 18 of the order it is stated the ECO administrator is responsible for approving alternative methodologies for suppliers to calculate carbon or cost savings. The window industry would like to propose the true carbon and financial savings are recognised under ECO and not the difference between current Building Regulation requirements for replacing windows and the actual installed product. 2. Who is obligated under ECO The GGF has no comments on this section of the consultation. 3. Notification of Domestic customer numbers and supply: setting obligations The GGF has no comments on this section of the consultation. Page 1 of 6

2 4. Achieving obligations: General information relating to all obligations Q3 If a supplier funds all or part of the installation of a measure, does this deem promotion of the measure. Also should we award only carbon savings that exceed building regulations? Replacement windows have been recognised for a considerable time as a measure which is energy saving and popular with the end consumer (this motivates the owner to improve the overall energy efficiency and carbon saving for the building). Energy efficient glazing and secondary glazing are listed within the measures for Green Deal however, there is some confusion regarding the terminology used. The GGF believe that there are the following types of improvement measures which should be included: Replacement windows this is when the whole window (frame and glazing) are removed and replaced. Secondary glazing this is when an additional layer of glazing is added to the building. Glazing improvements these are often neglected, but can have a significant impact on a building. This is when the current windows energy efficiency is improved. This could be when the window s insulating glass unit (IGU) is replaced for a higher specification product (frame stays in situ). Or there is a modification to the windows e.g. the application of a window film (this could be solar control to reduce excessive solar gains and reduce the requirement for air conditioning within the building). The GGF has concerns regarding the Chartered Surveyors report; we are not sure that the surveyor has sufficient knowledge on all the potential measures which could be adopted for a building. We would like to know the guidance and training provided by RICS to assure us that when appropriate upgrades to glazing are being considered. The GGF believes that the full carbon and energy saving for a measure should be recognised and not just the additional savings to the current building regulation requirements standards. For a window the majority of the carbon and energy savings will be to replace single glazed windows with double glazing; single glazing is often found in older hard to treat properties with occupants who cannot afford to pay for the replacement windows. The energy and cost savings as well as different costs for the windows were determined by the GGF in a Call for Evidence this took place December 2010; this has been provided with the GGF response but would prefer this not to be made publicly available To just recognise the carbon saving for the savings in excess of building regulation requirements would mean all the savings shown within the attached report are not taken into account. Page 2 of 6

3 The following table shows the difference for energy, carbon and CO2 savings for a detached house with 23.7m² of glazing with gas or electricity heating over 1 year and 25 years comparing replacement windows C rated or A rated. The difference is what ECO would recognise under the proposals: Heating Electricity Gas Replace window C rated A rated Difference C rated A rated Difference year years 11, , , , CO2 / year CO yrs Carbon / yr Carbon 25 yr This shows the substantial difference in savings over 25 years the electric heating system would save Tonnes of carbon, under ECO only 1.81 Tonnes would be recognised. Q4 Do you think the installation and technical standards required under ECO are sufficient? For the Glazing industry there are the competent person schemes for replacement windows, these were originally established in April 2002, so have a good track record for recording installations and checking a % for each registered installer for compliance against the Building Regulations applicable for replacement windows and doors. PAS 2030 recognise these requirements for compliance to Building Regulations through Annex R within PAS 2030: 2012 for energy efficient glazing and doors. Compliance methods against all the other clauses include establishing the requirements for contract review etc. FENSA, which is a company within the GGF Group, as well as being a competent person scheme operator for glazing also is UKAS accredited against PAS 2030 for windows and doors for certifying installation companies. If installers do not require PAS 2030 certification for ECO, this will have an impact on the number of installers prepared to gain certification; currently ECO is the drive for installers to gain this certification and not Green Deal. If OFGEM would allow competence of installers through the requirements of the annex (references the minimum technical competency for surveyors and Page 3 of 6

4 installers) and a tick box solution PAS 2030 clauses 1-8 this would mean installers would not have to go through the additional expense of certification which benefits the industry (particularly smaller installers who will not benefit from the economies of scale to cover the certification costs by large volumes of installation). However, if an installer is certified, this should be recognised and be an easier route for compliance. We believe the installer can be checked through competent person schemes without certification and still provide the assurance to the ECO administrator. We support the OFGEM proposal that all windows need to be replaced to make the installation complete. We would also raise that when solid wall insulation is being installed the glazing should ideally be replaced or at least re-installed. This is to reduce the potential for thermal bridging at the wall / window interface (the potential energy losses at the joint could have severe impact on the calculated savings for the building) as well as potential water ingress. Both of these faults could make substantial damage to the building fabric. 5. Carbon emissions reduction obligation The GGF would recommend that when solid wall insulation is being installed the glazing should ideally be replaced or at least re-installed. This is to reduce the potential for thermal bridging at the wall / window interface as well as potential water ingress. Both of these faults could make substantial damage to the building fabric. Q6 Hard to treat cavities The GGF do not feel suitably qualified to comment on this question within the consultation document. 6. Carbon saving community obligation Q7 views on requirement for walls and lofts to be insulated before district heating connections can be installed. The GGF support the view that walls and lofts should be suitably insulated prior to connection to district heating systems; the GGF believe the whole of the external envelope should be suitably insulated (including external windows and doors). The rationale is the same poorly insulated external envelope will mean the heat from district heating will be lost from the building. It should be remembered by reviewing the whole of the external envelope and ventilation, a good solution within reduced risk of condensation and failure will happen. 7. Home heating cost reduction obligation The GGF do not feel qualified to comment on affordable warmth group or boiler repair or replacement. Page 4 of 6

5 The GGF do feel that if window replacement is not feasible, repair and upgrade is something that should be considered under HHCRO. This could cover reglazing and refurbishment of windows as well as upgrading IGU s within an existing window. 8. Calculating savings 9. Q12 Use of SAP and RdSAP The GGF do have practical concerns on the use of this software to ensure the correct improvements are recognised i.e. correct identification of existing glazing (especially if old / first generation double glazing) and the specification for the new windows. In addition, there are defaults for determining window area based on floor area; the surveyor should measure and write in the actual window area to ensure the survey is accurate. Window glazing is identified with a lifetime of 20 years; this is often exceeded however guarantees are not normally provided for this length of time by window companies. This is not due to product failing, usually a guarantee failure will be early in the lifetime, later on this is down to poor or no maintenance or external factors such as subsidence. The in use factor of 15% for replacement glazing is just an additional safety factor; the GGF believe this is not required and we have sufficient confidence with the energy savings predicated for replacing windows. Q13 Scoring packages of measures. The GGF totally disagree with the proposal that savings for glazing is based on the additional savings to the current Building Regulation requirement for replacement windows. If you are replacing a single glazed window or first generation double glazed window the actual energy savings and carbon reduction should be taken into account to encourage the whole house approach. Please cross reference our response to Q4 for details on carbon and energy savings which are not taken into consideration. 10. Monthly notification of completed measures Q16 Approach to determine date measure installed and completed. The GGF would propose that competent person schemes be utilised for this purpose; an installer registers jobs as being complete and installed to meet the requirements of the scheme; this can be flagged as an ECO job, which would mean a report goes from the competent person scheme operator to OFGEM and not rely on the energy company. 11. Transfers of qualifying action Page 5 of 6

6 The GGF do not feel suitably qualified to respond to this section of the consultation. 12. Excess actions The GGF do not feel suitably qualified to respond to this section of the consultation. 13. End of overall obligation period The GGF do not feel suitably qualified to respond to this section of the consultation. 14. Audit and technical monitoring Q21 Technical monitoring The GGF would propose that the use of competent persons schemes ties in very well with the ECO requirement for technical monitoring. The CPS operator will undertake site audits already therefore to extend to cover ECO requirements is a logical solution. Giles Willson Deputy Chief Executive and Director for Technical Affairs Glass and Glazing Federation Page 6 of 6

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