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The Bfrc Window Energy Rating Scheme From Glasstalk
Dear Customer, We feel that it is incumbent on Thermoseal Group to inform you of our concerns regarding the development of the GGF/BFRC WER scheme. Please note the following comments summarise our views based on the limited information supplied to Thermoseal Group by the GGF/BFRC. We suggest you contact the GGF/BFRC for clarification on the points raised and we recommend that individuals check the facts for themselves.
- Under the consultation papers issued by the Department for Communities and Local Government in June 2009, the proposed amendments to Part L essentially mean that in existing dwellings, to show compliance with the Building Regulations it will be necessary to ensure that windows are fitted that have a minimum WER (Window Energy Rating) of Band C. The effect of this is that the WER scheme becomes the single performance standard by which to show compliance with Part L in respect of controlled units in the UK.
- As the BFRC is the sole organisation to administer the WER scheme, it follows that the BFRC is effectively the monopoly provider of the WER in the UK. It is the only organisation set up as an approver of simulations and the sole organisation with which to register for a WER. It is the sole provider of licences. The BFRC provides an economic service to those requiring simulations and licences as it charges fees for these services.
- The rating and licence that the BFRC provides is for the entire window unit. I.e. a rating will only be given in relation to a complete unit and not to individual components that make up the unit. In simple terms this means that should one of those components change (e.g. the glass), even if that component is of the same or superior specification, the previous rating will not apply and a new simulation must be carried out and paid for.
- We believe the current BFRC scheme unfairly favours window companies and fabricators. It does not offer any method for a glass sealed unit manufacturer to demonstrate compliance with the regulations. At present many installers and window companies (i.e. the companies that fit windows to properties and deal with the end consumer) buy their window frames from fabricators and their glass from sealed unit manufacturers. The WER scheme effectively means that fabricators are consolidating control of the market by refusing to allow customers (the installers etc) to use their license unless they purchase their sealed units from them.
- The proposed WER scheme stops new IG products from entering the UK market. Once a fabricator or window company has a simulation with a selection of WER products listed, there is no incentive to improve or innovate on the units with superior components. This is due to the extra costs associated with arranging for further simulations.
- Under the scheme, sealed unit components will be chosen by the official simulators acting on behalf of the window fabricator or supplier. This means that the sealed unit manufacture will have no control over the makeup of the unit and so will be forced to supply a product exactly to the specification (including brand naming) as dictated by the original simulation. It also means that in order to gain access to the full market, an IGU producer would have to stock every brand of component and use every different type of production method. Clearly this would be impossible.
Thermoseal Group supports the introduction of a Window Energy Rating Scheme and believes that the GGF is the best organisation to administer this scheme. However, for the scheme to work it must be fair and open. If you are concerned and would like to express your views regarding any aspects of the scheme, or if you would like some guidance and clarification of the guidelines of the scheme visit www.gasstalk.co.uk.