Energy Bill [Lords]

Memorandum submitted by Glass and Glazing Federation (EN 23)

1. Summary

1.1. The Glass and Glazing Federation (GGF) is the leading authority for employers and companies in the flat glass, glazing, home improvement and window film industries. Its key focus is on consumer protection and improving the energy efficiency of households and commercial premises, and it is currently engaging across government to review how Energy Efficient Windows can support the green agenda.

1.2. This evidence relates to the provisions for the Green Deal contained within the Energy Security and Green Economy Bill (HL).

1.3. The GGF supports the government in its efforts to increase the energy efficiency of homes through the introduction of the Green Deal. In order to ensure that the Green Deal delivers most benefit to consumers, industry and Government, the GGF believes that a ‘whole house’ approach to energy efficiency should be adopted to maximise impact.

1.4. The GGF also strongly advocates maximum access for consumers; fair competition between manufacturers and installers of energy efficient products; and consumer protection.

2. The GGF’s focus

2.1. The Glass and Glazing Federation (GGF) is the leading authority for employers and companies in the flat glass, glazing, home improvement and window film industries.

2.2. Consumer protection is a key role of the GGF, and it provides valuable protection for consumers from beginning to end of any dispute resolution .

2.3. All GGF members are vetted; must carry out their work to specified standards; are required to participate in the GGF Deposit Protection scheme where they take deposits from a private consumer; and must offer independent arbitration should the need arise.

2.4. The GGF also established the Fenestration Self-Assessment Scheme (FENSA) , in 2002. FENSA has issued over 7 million window and door homeowner certificates and is the recognised double glazing industry leader. All FENSA registered businesses (and those of all windows competent persons schemes) are obliged to offer an Insurance Backed Guarantee..

2.5. A further key aim of the GGF is improving the energy efficiency of households and commercial premises.

3. The importance of including Energy Efficient Windows in the Green Deal

3.1. The introduction of the Green Deal is of enormous significance to all manufacturers and installers of energy efficiency products for buildings, and represents a vital opportunity to ensure that the glass and glazing industry benefits from the government’s energy efficiency drive.

3.2. Initially, it was suggested by officials at the Department for Energy and Climate Change that Energy Efficient Windows may not have any role to play in the Green Deal, due to the perception of consistently high costs, and a lack of awareness of the crucial contribution that they make to the energy efficiency of a building.

3.3. The GGF have therefore been campaigning to highlight the energy efficiency properties of windows to Parliament and Government, and have undertaken a major research project in order to demonstrate the role that glass and windows can play in reducing household energy bills and carbon emissions.

3.4. The Energy Saving Trust estimated that approximately 23% of a building’s heat energy is lost through inefficient windows. GGF research demonstrates that, if Energy Efficient Windows were installed in all properties of the existing housing stock this would reduce national emissions by 10%, as well as reducing national domestic energy expenditure by 10%.

3.5. The average yearly saving made by converting all existing housing stock windows to Energy Efficient Windows would be:

3,970,663 tonnes of carbon

14,559,098 tonnes of CO2

£2,363 million

3.6. The average yearly energy bill savings made for installing Energy Efficient Windows in a typical GB house would be:

£150.49 in a single glazed house (up to £325 in an electrically heated house)

£44.88 in a double glazed house (pre 2002)

3.7. A recent report [1] by the Energy Saving Trust confirmed that replacing inefficient windows is one of the key measures necessary to improve certain E and F energy-rated homes.

3.8. Data relating to the average cost of windows, insofar as that may be established, may be found in appendices 1 and 2.

3.9. It is therefore vital that Energy Efficient Windows be included in the list of measures eligible for support under the Green Deal , if their cost meets the Golden Rule in individual cases.

3.10. Other energy efficiency measures, and therefore industries, have long been supported by government policy. The Green Deal has the potential to boost industry by levelling the playing field, and ensuring that all energy efficiency measures have fair access to the market for energy efficiency measures.

4. Ensuring that the Green Deal has the best result for consumers, industry, and the government

4.1. The Green Deal should adopt a ‘whole house’ approach

A ‘whole house’ approach would enable householders to get the most out of the Green Deal, and assist a rapid transition to a low-energy, low-carbon economy. Maximising opportunities for householders to retrofit their homes with Energy Efficient Windows is a key method of meeting the high level ambitions for reducing greenhouse gas emissions that the Government has displayed in its 4th Carbon Budget.

4.2. The ‘whole house’ approach would also provide a much needed boost to employment opportunities. The funding of Energy Efficient Windows through the Green Deal could potentially create jobs for 10,000 installers, as well as additional jobs within the rest of the supply chain.

4.3. The Green Deal must provide consumer choice

The GGF believes that householders should be given the choice over what eligible energy efficiency measures are installed, and who is to install them. This will help to maximise the impact of the Green Deal, particularly in conjunction with a ‘whole house’ approach.

4.4. The Green Deal must provide consumer protection

The GGF fully supports the principles of consumer protection and quality assurance, with all work being carried out proficiently by skilled contractors and installers free of bias . The GGF supports these principles being implemented with a mindfulness of the burden that undue levels of bureaucracy can place upon businesses.

4.5. The Green Deal should support industry

The GGF estimates that funding Energy Efficient Windo ws through the Green Deal could potentially create jobs for 10,000 installers, as well as additional jobs within the rest of the supply chain. This is crucial for industry given that, in 2010, figures for windows installations were almost 30% lower than in 2004, and the workforce had fallen by almost 10,000 people during the same period. All contractors and installers, of all sizes, should have equal opportunity to benefit from the implementation of the Green Deal.

4.6. The Green Deal should complement other Government policies

The GGF believes that Government must consider how the Green Deal can fit with other carbon reduction polices, Building Regulations, other Competent Persons Schemes and reduced rates of VAT, in order for it to have maximum impact upon carbon emissions.  

4.7. Incentives must be introduced to ensure Green Deal uptake

For the Green Deal to be effective, it is important that there are sufficient incentives for uptake. The government has yet to clarify how consumers of the Green Deal are to be incentivised to get involved, and what benefits they will receive in return, without which it is unlikely that it will have its desired effects.

4.8. The Green Deal market must be open to small and medium sized businesses

The government has stated its commitment to SMEs, and it is important to ensure that the provisions for the Green Deal do not preclude smaller operators from entering the market.

Appendix 1 - Evidence on the Costs and Benefits of Energy Efficient Measures

1. Background

This information has been collated by the Glass and Glazing Federation (GGF) following discussions and feedback from the Trade Associations representing the industry namely British Plastics Federation, British Woodworking Federation, Council for Aluminium in Buildings and Steel Window Association.

An exercise was undertaken in December 2010 to determine the costs of replacing windows for 7 domestic properties. The work was undertaken by quoting against the technical surveys for the property. The quotations covered all framing materials and were for installing a compliant Building regulation product. The prices were averaged to cover all the framing material types.

The average costs and energy savings are contained within Appendix A of this report.

2. Response to the information requested.

2.1 Product information.

Replacement energy efficient windows and doors (windows with a U value 1.6 or better / WER band C and doors U value 1.8 or better).

Covering all framing materials i.e. timber, PVC-U, Steel and aluminium

All styles of windows e.g. casement, vertical slider, tilt turn, pivot, pedestrian door sets, sliding patio doors, bi fold doors.

These products can be installed in domestic and non domestic buildings.

2.2 Total cost for professionally installing these measures for different types of property and locations

The economic case for replacing existing windows with energy efficient products has been difficult to determine due to the large variations in size, style and number of windows, as well as particular site requirements for access and health and safety for operatives installing the product. Full details of the costs and savings are contained within Annex A of this report.

It does appear from this exercise that replacement windows do pay back with the economic fuel savings to be made on certain properties and therefore should be an energy saving measure included within Green Deal.

Sites 3 and 4 (details in Appendix A), the payback periods were worse; this was due to both sites having a large number of smaller windows. Therefore with higher costs and less area for savings the payback period is longer.

Site 5 we had 2 quotations; one for a fixed light with a top hung opener and the original styled vertical sliding sash. There was a substantial difference in price (the original style being more expensive) despite the same energy savings regardless of the window style.

Other benefits following the replacement of windows have not been included with this survey e.g. reduced maintenance costs, increased home security and improved sound insulation.

2.3 Assumptions behind the costs

There were 7 properties with technical surveys to quote against:

Site 1 – 2 bedrooms detached 9 windows

Site 2 – 4 bedroom detached – 12 windows

Site 3 – 3 bedrooms terraced – 8 windows

Site 4 – 2 bedrooms terraced – 8 windows

Site 5 – 3 bedroom semi detached – 8 windows – top hung and fixed light

Site 5 – 3 bedroom semi detached – 8 windows – vertical slider option

Site 6 – Terraced 2 windows for replacement

Site 7 – Detached 1 bedroom – 4 windows

There were no site inspections before the quotations were prepared.

The replacement window specification:

PVC-U (white) or Timber.

Building regulation minimum compliant window for thermal performance i.e. U value 1.6 or WER band C

Safety glazing was not quoted for any windows

Site 5 there are 2 window options – top hung with fixed lights as shown on the survey and vertical slider as an alternative.

The lowest selling price was quoted i.e. quoted as if it were a competitive tendering situation.

The costs cover the removal of the existing window from site and the supply and installation of the specified replacement window

No doors were included within quotation.

VAT was quoted at the current 17.5% rate; however this has also been calculated using the reduced VAT rate (5%) to enable a payback time period to be calculated using current fuel prices (which charge the reduced rate VAT).

The annual savings did not include any inflation and therefore can be used to determine the actual payback time. This used an average installation cost for each site where VAT was calculated at the reduced rate (same as the fuel VAT rate) to enable a true comparison.

It should be noted that with heating savings indicated within this report; due to Government policy already announced to migrate fuel source from gas to electric, and with energy prices expected to increase over future years by considerably more than general inflation, the actual payback periods are likely to be considerably better than those scheduled on a simple "year 1" saving basis."

2.4 Average time to install measures

This will vary significantly depending on the size and complexity of the contract.

To replace a single window could take half a day.

To replace a 3 bedroom house of windows and doors 3-4 days

To replace 385 windows over a 9 floor non domestic building 11 months

In addition there needs to be time for a technical survey prior to the manufacture of the replacement windows and doors; for a typical domestic location this is half a day.

2.5 Energy saving performance of the measures

The details for the energy savings for each site is detailed within Appendix A.

The carbon, CO2 and fuel price savings for the actual windows replaced have been calculated for 1, 20, 25 and 30 years using a variety of fuel types for the different properties.

The calculations for energy savings were determined using the GGF Energy Savings calculator; this can be found at www.ggf.org.uk

The GGF Energy Savings Calculator was developed with consultation with the Energy Saving Trust who have reviewed and accepted its method of operation and function.

2.6 Method for determining costs

Through the Trade Associations listed at the start of the report and through electronic trade media all replacement window companies were invited to submit their quotations for the cost of replacing windows for the 7 sites provided. These prices were submitted to the GGF for collation.

To protect all parties regarding prices for replacing windows; no company names were included with the summary sheet. The GGF had one person collecting the raw data and ensuring there is no link between prices and a particular company, the quotations were all tabulated for analysis.

The frame material type has been removed from the report.

2.7 Other cost factors

The costs and the energy savings were assuming the original windows were in correct working order and with no drafts or breakages – these effects would make the energy savings far greater.

2.8 Lifetime and replacement rate

The general rule from practical industry experience and in line with BRE research is windows and doors will have a lifetime of approximately 35 years. There will be maintenance required during the life of the windows; if this is not undertaken the lifetime will be considerably reduced.

2.9 Costs and benefits for packages of measures.

There is no current supporting evidence for the costs and savings for packages of measures to be undertaken however the following other measures installed with replacement windows and doors would make significant energy efficiency savings for the building:

· Solid wall insulation – both internal and particularly external.

· Cavity wall insulation

· Roof insulation

· Floor insulation

These measures combined would upgrade the entire external envelope of the building making substantial energy savings. Additional research is required to determine the cost benefit of installing multiple measures to a building.

2.10 Tools and methodologies for determining calculation of performance

The performance of the replacement windows was determined using the GGF energy calculator this can be found at www.ggf.org.uk

The GGF Energy Savings Calculator was developed with consultation with the Energy Saving Trust who have reviewed and accepted its method of operation and function.

2.11 Technical risks associated with installation or improper maintenance

If a building has replacement windows installed by a competent company there is very little technical risk; the technology is well proven with a lot of industry experience.

If the replacement windows and doors are not properly maintained; this could result in early failure and the product not reaching its expected product life.

It should be noted that maintenance is not difficult, generally requiring regular cleaning and lubrication of moving parts.

2.12 Evidence of technical problems

When installing replacement windows and doors in existing buildings the following need to be taken into consideration and may have an impact on the costs:

Building Structure

· DPC’s missing, damaged or inadequate

· Special internal finishes

· Special external finishes (Stonework)

· Opening structurally inadequate

o Surrounding building structure showing signs of distress before original windows removed

· Structure not able to take modern fixings

o Crumbles when original windows are removed

o Original fixings cannot be removed (have to avoid them when fitting new windows)

· Asbestos in building structure

Occupant limitations

· Do they have disabilities and require specialist applications

· Do they need to remain in the property or can they leave whilst the work is carried out

· Is there health likely to be affected by the works being carried out

Internal access

· Height of window openings above FFL

· Weight of windows, can they be handled by 1 or more people or specialist lifting equipment

· Size of windows, can they be installed from the inside

· Layout inside building (corridors, internal doorways, stairs, lifts, etc) heights, widths, and any weight limits

· Fixed & moveable equipment in the way

· Fixed & moveable furniture in the way

External access

· Height of window openings from ground level

· Requirement for access equipment (scaffolding, scissor lifts, hydraulic platforms, etc)

o Condition of external surfaces to support access equipment, flatness, ability to withstand loadings from access equipment

o Access to all locations with access equipment

Protection

· Requirements for protection of equipment, possessions, finishes and surfaces, etc internally

· Requirements for protection of external finishes & surfaces, equipment (e.g. air con units), walkways. etc

Services

· Availability, and continuity, of services such as water, electricity, and facilities such as washrooms, toilets, messrooms.

Health, Safety & Security

· Any special needs of the occupants or those who can access internally while work is being carried out.

· Any special needs of the general public outside the building.

· Safe storage of materials on site.

· Handling of materials on site.

· Security on site

· Criminal Records Background (CRB) check on installer and site staff

2.13 Research work

The GGF is currently undertaking research work on the following measures:

A) Replacing and upgrading insulating glass units within existing (pre 2002) double glazed windows to improve the thermal performance of the building.

B) Application of film on the existing glass to improve thermal performance

C) Application of film on existing glass to reduce excessive solar gain

Appendix 2 - Summary of test data for each site

Site 1

Property - 2 bedrooms detached
Overall window area				23.15 m2
Number of windows				9
Average replacement cost				£3,533.58 (VAT 17.5%) £3,157.67 (VAT 5%)
Time Period / inflation Rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£279.38	£191.68		£256.66
Payback		11.3 yr	16.5yr		12.3yr
20 yrs 4%	£ CO2 C	£8,290 37.84 10.32	£5,610 19.26 5.25		£7,631 21.71 5.92
25 yrs 4%	£ CO2 C	£11,593 47.29 12.90	£7,846 24.08 6.57		£10,672 27.14 7.40
30 yrs 4%	£ CO2 C	£15,613 56.75 15.48	£10,567 28.89 7.88		£14,372 32.57 8.88

Site 2

Property – 4 bedrooms semi detached
Overall window area				20.7m2
Number of windows				12
Average cost of windows				£4,401.85 (VAT 17.5%) £3,933.57 (VAT 5%)
Time Period / inflation rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£249.81	£171.39		£229.50
Payback		15.7yr	23yr		17.1yr
20 yrs 4%	£ CO2 C	£7,410 33.82 9.22	£5,015 17.22 4.70		£6,821 19.41 5.29
25 yrs 4%	£ CO2 C	£10,363 42.28 11.53	£7.014 21.52 5.87		£9,539 24.26 6.62
30 yrs 4%	£ CO2 C	£13,956 50.73 13.84	9,446 25.83 7.04		£12,847 29.11 7.94

Site 3

Property– 3 bedrooms terrace
Overall window area				12m2
Number of windows				8
Average cost of windows				£4,123.61(VAT 17.5%) £3,684.93 (VAT 5%)
Time Period / inflation rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£144.82	£99.36		£133.04
Payback		25.4yr	37yr		27.7yr
20 yrs 4%	£ CO2 C	£4,296 19.61 5.35	£2,907 9.98 2.72		£3,954 11.25 3.07
25 yrs 4%	£ CO2 C	£6,008 24.51 6.68	£4,066 12.48 3.40		£5,530 14.06 3.84
30 yrs 4%	£ CO2 C	£8,091 29.41 8.02	£5,476 14.97 4.08		£7,448 16.88 4.60

Site 4

Property – 2 bedroom terraced
Overall window area				9.54m2
Number of windows				8
Average cost of windows				£2,614.38(VAT 17.5%) £2,336.25 (VAT 5%)
Time Period / inflation rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£115.13	£78.99		£105.77
Payback		20.3yr	29.6yr		22.1yr
20 yrs 4%	£ CO2 C	£3,415 15.59 4.25	£2,311 7.94 2.16		£3,144 8.94 2.44
25 yrs 4%	£ CO2 C	£4,776 19.48 5.31	£3,233 9.92 2.71		£4,396 11.18 3.05
30 yrs 4%	£ CO2 C	£6,432 23.38 6.38	£4,353 11.90 3.25		£5,921 13.42 3.66

Site 5

Property – 3 bedroom semi detached
Overall window area				15.45m2
Number of windows				8
Average cost of windows – fixed light and top hung casement				£2,707.16(VAT 17.5%) £2,419.16 (VAT 5%)
Average cost of windows – vertical sliders				£6,817.25 (VAT 17.5%) £6,092.01 (VAT 5%)
Time Period / inflation rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£186.45	£127.92		£171.29
Payback Fixed light		13.0yr	18.9yr		14.1yr
Payback Vertical slider		32.7yr	47.6yr		35.6yr
20 yrs 4%	£ CO2 C	5,531 25.24 6.88	3,743 12.85 3.50		5,091 14.49 3.95
25 yrs 4%	£ CO2 C	7,735 31.55 8.61	5,235 16.06 4.38		7,120 18.11 4.94
30 yrs 4%	£ CO2 C	10,417 37.87 10.33	7,050 09.28 5.26		9,589 21.73 5.93

Site 6

Property – terraced 2 windows
Overall window area				7.26m2
Number of windows				2
Average cost of windows				£916.06 VAT 17.5%) £818.61 (VAT 5%)
Time Period / inflation rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£87.62	£60.11		£80.49
Payback		9.3 yr	13.6 yr		10.2 yr
20 yrs 4%	£ CO2 C	2,599 11.86 3.24	1,759 6.04 1.65		2,392 6.81 1.86
25 yrs 4%	£ CO2 C	3,635 14.83 4.04	2,460 7.55 2.06		3,346 8.51 2.32
30 yrs 4%	£ CO2 C	4,895 17.79 4.85	3,313 9.06 2.47		4,506 10.21 2.78

Site 7

Property – 1 bedroom detached
Overall window area				19.6m2
Number of windows				4
Average cost of windows				£1,289.11 (VAT 17.5%) £1.151.97 (VAT 5%)
Time Period / inflation rate
		Energy and fuel savings
		Heating type
		Electricity	Gas		Oil
1yr 0%		£236.54	£162.28		£217.30
Payback		4.9 yr	7.1 yr		5.3 yr
20 yrs 4%	£ CO2 C	£7,016 32.02 8.73	£4,749 16.30 4.45		£6,459 18.38 5.01
25 yrs 4%	£ CO2 C	£9,813 40.03 10.92	£6.641 20.38 5.56		£9.033 22.97 6.26
30 yrs 4%	£ CO2 C	£13,215 48.04 13.10	£8,944 24.46 6.67		£12,164 27.57 7.52

June 2011