Energy Bill

The Association of Controls Manufacturers (EN 29)

Submission to the House of Commons Public Bill Committee Inquiry: Energy Bill

The Association of Controls Manufacturers ( TACMA )

1. TACMA, the heating control manufacturer s association within BEAMA, represents UK manufacturers and suppliers of electrical and electronic controls and valves used in domestic heating a nd hot water systems. Heating and hot water controls are necessary to allow householders to achieve both comfort and energy efficiency , and to empower individuals to manage their energy use.

2. TACMA welcomes the opportunity to submit evidence to the Public Bill Committee inquiry into the Energy Bill and looks forward to further engaging with the Committee on this Inquiry as it progresses. TACMA is available to provide supplementary oral and written evidence to the Committee.

Executive Summary

3. The Green Deal is an enormous opportunity for Government and industry to work together to deliver real change in the energy efficiency of existing housing. A focus on heating (heating appliances, heating controls and insulation together) is most likely to deliver this ambition.

4. Heating controls can meet the ‘golden rule’ by providing cost effective energy savings. However, their presence is also necessary to ensure that predicted savings of other measures such as insulation can be achieved in practice. To maintain the integrity of the scheme i t should therefore be mandatory to ensure that homes have a minimum level of controls when receiving a green deal offer.

5. Making heating systems the focus of the Green Deal rather than the offer of a ‘green makeover’ could provide a more compelling offering to consumers. It would also avoid over-c o mplication of the scheme while still addressing 82% of the energy used in homes, which is for heating and hot water. [1]


The Importance of the Green Deal

6. The Green Deal is likely to stand as the primary policy tool to drive energy savings in existing homes. As such, it stands as both an immense opportunity for industry to help Government deliver energy saving technologies on the scale required, and also as a responsibility for all parties to ensure that it works. If this scheme fails to deliver on its potential then the UK is likely to fail to hit its carbon reduction targets, certainly to 2020 and possibly beyond.

7. We believe that there are a number of key criteria that Government must address in setting out the legislation for the Green Deal through the Energy Bill. These are that the scheme must:

a. Provide a compelling offer to consumers to drive take-up.

b. Avoid over-complexity and excess bureaucracy.

c. Focus on the most important measures that deliver the biggest energy savings.

d. Take opportunities for the installation of ‘enabling technologies’ as part of every Green Deal offer.

We believe that a greater focus on heating systems, and in particular the role of heating controls can help achieve these criteria as detailed below.

The Role of Heating Controls in the Green Deal

8. In our submission to DECC as part of their call for evidence on technologies (appendix 1) we were able to demonstrate that a number of core domestic control technologies can meet the ‘Golden Rule’ providing cost-effective energy savings to consumers.

9. Principle among these is the simple room thermostat, a device that turns off the boiler when the desired internal temperature has been reached. Work carried out by TACMA with the Energy Saving Trust identified that 8 million UK homes with a boiler don’t have a room thermostat [2] . This means that there is significant scope for energy savings from the retrofit application of room thermostats alone.

10. The current Building Regulations Part L (energy conservation) recognise the necessity of controls for a heating system to operate efficiently. To comply with these regulations a new heating system needs to be installed with a room thermostat, a programmer and TRVs (Thermostatic Radiator Valves – devices that control the heat ouput of individual radiators to allow independent temperature control in each room.) However, the same work with the Energy saving Trust referred to in paragraph 9 showed that about 70% of UK homes don’t currently have this minimum level of controls.

11. Programmers and TRVs are not well treated with the Government’s approved methodology for calculating the energy saving impact of measures (SAP.) This is because the SAP methodology assumes standard occupancy conditions before and after a measure is installed. This means that, for example, a programmer would not affect the assumed operational hours of a boiler within SAP even though the role of a programmer is to ensure that the heating system is automatically switched on and off so that it only operates when required. The net result of this is that it is difficult for some control technologies to meet the ‘golden rule’ when analysed under SAP. Yet if these controls are not present then the basis on which the impact of any energy efficiency measure is assessed under SAP will be flawed because the assumed standard occupancy conditions cannot be achieved.

12. The issue for Government is that the Green Deal is predicated on the fact that consumers will be taking on additional costs on their energy bill against a predicted saving in these bills. For the Green Deal to have any credibility we must ensure that the predicted savings are possible to achieve and this will only be the case if controls are in place to maintain the occupancy conditions against which the savings are predicted. TACMA believes that there is a good case for controls to be seen as ‘enabling technologies’ for any Green Deal offer and that properties should achieve a minimum controls specification (e.g. a room thermostat and programmer) when any measures are installed. This would ensure the following:

a. That predicted savings from measures can be achieved in practice. For example ensuring that cavity wall insulation results in less energy use rather than higher internal temperatures.

b. That building occupants will have the ability to use the controls to manage their energy use to reduce their bills further. While they will also be theoretically able to choose higher temperatures or longer operating hours for their heating system this will at least be their choice and not something they can blame on the Green Deal.

13. We understand that SAP, or the BREDEM methodology on which it is based, is almost certain to serve as the underlying calculation methodology for the Green Deal and therefore that any products covered under the Green Deal will need to be within this calculation methodology. There are a number of currently available control technologies (e.g. modulating room thermostats, programmable TRVs) that provide the option for further control savings but are not currently recognised in the calculation methodology. Despite this being acknowledged by Government back in 2008 [3] there has been no progress on rectifying this. We don’t believe that this is in the interests of industry,householders or Government, who would like to see energy saving technologies brought to market as quickly as possible.

The Benefits of a Greater Focus on Heating Systems in the Green Deal

14. Heating and hot water accounts for 82% of the energy use in an average home. It should therefore have a prime focus in the Green Deal by promoting the key ways of reducing this energy use . The main technologies that do this being heating controls, higher efficiency heating appliances, and insulation. Such a focus would also serve to demystify the offereings and avoid the tendency to over complicate what can be done in homes to reduce energy use.

15. TACMA believes that the Green Deal is most likely to be successful if presented as a scheme for new heating systems, where there is a requirement to also install a high level of controls and insulation. Consumers already know that they want to be warm, and recognise that replacement of their boiler is likely to be expensive and likely to need to be done at an inconvenient time (e.g. when it breaks down in the winter.) All evidence from schemes such as the boiler scrappage scheme is that heating schemes are more successful in terms of take up compared to schemes offering general energy efficiency because the customer demand already exists. A well structured heating and efficiency scheme would, at the same time, be tackling the largest proportion of energy use in homes, hence achieveing widespread energy savings.

16. Those dwelling where the replacement of the heating appliance was uneconomic could receive the controls and insulation elements only; achieving energy savings immediately and also making the system and structure suitable for when the appliance was eventually replaced. Such a scheme, particularly as it matured, would also be a perfect mechanism through which to deliver renewable heating options such as heat pumps.

17. A further advantage of a focus on heating is that there is already a mature supply chain. Around 5,000 gas or oil boilers are installed every day, and there are many more interactions with householders for servicing and repairs. As long as independent installers are fully involved this would be an excellent basis for communication and delivery of the Green Deal scheme.

18. In setting out the legislation in the Energy Bill in relation to the Green Deal, TACMA believes that the following are essential:

a. That the application of the scheme should allow for some measures to be mandatory when a Green Deal offering is made. This should allow either a requirement for basic controls as ‘enabling technologies’ so that predicted energy savings can be delivered, or a requirement for insulation and controls to be installed with a new heating appliance so that full heating savings can be delivered.

b. It should be possible for customers to take on additional repayments that fall outside of the golden rule as part of the Green Deal offering – specifically to facilitate the take up of efficient heating systems. In such cases customers would see the additional benefits such as better comfort and flexibility and be willing to take on costs for more than just energy savings.

c. The legislation should make it possible for small, independent installers to take part in the scheme. In particular the costs and bureaucracy should be limited both to encourage small installers but also to restrict the costs that will otherwise be passed on to consumers.

June 2011

APPENDIX 1 – TACMA Submission to the DECC Call for evidence on energy saving technologies

Domestic Heating Controls


Heating controls are a proven, cost-effective energy saving technology that have been utilised in homes for over sixty years. Their role in home energy efficiency has been recognised for some years in Government policy, particularly through the Building Regulations and CERT.

However, the need to install effective heating controls has rarely been prominent in consumer messages on energy saving. We believe that this is partly to do with a perceived complexity, and partly because of an assumption that, since the installation of controls is mandated with boiler replacements, the job of getting controls installed in UK homes is done.

The fact is that at present there are around 8 million UK homes without a simple room thermostat, and 70% of existing homes don’t have the minimal level of controls specified in the building regulations.

The controls industry is pleased at this opportunity to submit evidence for the Green Deal. We have focussed our evidence on the most basic control measures that will fit within the ‘golden rule.’ These will provide simple messages for consumers and Green Deal providers, yet at the same time will tackle the most pressing problems of inadequate control in our homes. We would like these fundamental measures to form a starting point from which more sophisticated control systems can be offered through the Green Deal.

For this ambitious policy measure to work it will be essential that installed measures deliver the predicted energy savings that Green Deal recipients will be expecting. This factor makes it very important that controls are in place for the following reasons:

- Predicted energy savings for heating measures (including insulation) are based on assumptions on operational hours of the heating system and internal temperatures. Yet it is only though controls that operational hours can be set and internal temperatures maintained with any confidence. Consideration should therefore be given to making it compulsory for homes to also be brought up to a minimum controls standard when any other heating or insulation measure is installed under the Green Deal.

- The correct use of controls is necessary in order for the predicted energy savings to be achieved in practice, and can also offer opportunities for further behavioural savings to be made. As part of this proposal TACMA would commit to working with Government to produce user-friendly guidance for control systems that Green Deal providers can utilise to ensure that recipients manage their energy effectively and therefore achieve the predicted (or better) energy savings.

Proposed control options

TACMA proposes that the following options should for the basis of eligible heating control measures in the Green Deal:

1. For homes without a room thermostat, a new electronic room thermostat to be installed.

2. For homes without a room thermostat and programmer, a new programmable room thermostat to be installed.

3. For homes without TRVs (thermostatic radiator valves) that also don’t have cavity wall insulation, TRVs to be installed as a package with the insulation to prevent subsequent overheating.

We also propose that an ‘innovation’ option is established so that there is a clear path for advanced control options to be incorporated into the Green Deal subject to provision of a clearly specified evidence base.

Options 1-3 can be shown to meet the golden rule using savings data from the SAP calculation methodology and cost data sourced from installers. A summary of these can be found below:

2-bed flat

3-bed semi.

4-bed det.

Option 1

Room thermostat


Installed cost








Cost/month over lifetime




Estimated savings




Savings/ month




Net financial impact/month




Option 2

Programmable room thermostat


Installed cost








Cost/month over lifetime




Estimated savings




Savings/ month




Net financial impact/month




Option 3

TRVs with cavity wall insulation

Installed cost








Cost/month over lifetime




Estimated savings




Savings/ month




Net financial impact/month




- Savings for room thermostats and TRVs taken from the CERT spreadsheet, derived from SAP.

- Savings for programmable room thermostats based on room thermostat savings with an uplift of 50% to account for variable time setting function.

- Fuel costs based on cost of gas at £0.041/kWh.

- Installation costs based on information from installers plus assumed 8% interest rates.

- Lifetime for controls from CERT spreadsheet and European standards.

Evidence base

The full evidence base and numbers are detailed in the spreadsheet to be read with this paper. However the commentary below is intended to supplement this data.


The TACMA proposal attempts to align Green Deal heating controls measures with the requirements of the building regulations to bring existing dwellings up to a reasonable standard of control. The 2010 Domestic Building Services Compliance Guide, which provides statutory guidance on minimum standards, recommends the fitting of time and temperature control for both heating and hot water, with further recommendations for the zoning of the space heating.

In the context of existing building upgrades, TACMA recognise that some of the measures described in the compliance guide require substantial alterations to system pipe-work which is both disruptive and prohibitively expensive unless carried out as part of a larger measure. The TACMA Green Deal proposals attempts to remove the cost and disruption barrier to an upgrade of controls by focussing on the provision of space temperature control through the provision of an electric/electronic room thermostat. In addition, where the initial assessment identifies that the heating system is not equipped with a timer or programmer, the installation of a programmable room thermostat can provide both time and temperature control of the system for a small additional cost. The incorporation of a room thermostat, with or without timer, will also provide the essential boiler interlock to bring the overall system close to the building regulations minimum standards. A boiler interlock is not a physical control device but a system of wiring to ensure that the boiler switches off when there is no demand for heating. This is essential to minimise the energy use of the heating system.

Energy saving claims; room thermostats

Figures for the energy savings from the installation of a room thermostat in different property types are taken from the CERT spreadsheet used by energy suppliers to claim carbon reductions. The data in the CERT spreadsheet comes from the Standard Assessment Procedure (SAP.)

The Standard Assessment Procedure (SAP) is DECC's methodology for assessing and comparing the energy and environmental performance of dwellings. Its purpose is to provide accurate and reliable assessments of dwelling energy performances that are needed to underpin energy and environmental policy initiatives. SAP works by assessing how much energy a dwelling will consume and how much carbon dioxide (CO2 ) will be emitted in delivering a defined level of comfort and service provision, based on standardised occupancy conditions. The SAP methodology is based on the BRE’s Domestic Energy Model (BREDEM), which provides a framework for calculating the energy consumption of dwellings. BREDEM predictions have been subjected to rigorous tests, comparing them to actual energy use in dwellings as well as with more detailed simulation models. Given all of the necessary input data, the model’s annual space heating energy use predictions are typically within about 10 per cent of actual measurements.

SAP, and BREDEM are used to underpin the delivery of a number of key energy and environmental initiatives, for example the Buildings Regulations for England and Wales and the Devolved Administrations relating to the conservation of heat and power, where SAP is the method specified for assessing compliance; HM Treasury’s Stamp Duty exemption for zero carbon homes; National Calculation Methodology, as specified by the Energy Performance of Buildings Directive, SAP and RDSAP are used to produce Energy Performance Certificates; Local Authority stock reporting, etc.

Table 4C in SAP provides evidence of the negative effect of not having a room thermostat by applying a penalty of -5% to space heating seasonal efficiency and table 4E an increase in mean internal temperature of 0.6oC.

Energy saving claims; programmable room thermostats

Energy savings from the temperature control function is described above. However SAP gives no merit for the fitting of a time control, despite the underlying assumptions within SAP that the heating system will operate against a standardised time profile of 11 hours/day Mon-Fri, and 16 hours/day Sat-Sun which is embedded within the SAP calculation methodology. SAP also has no facility to evaluate the impact of different temperature profiles, but instead assumes a space temperature of 21oC which is corrected up or down according to other influences including control type.

TACMA firmly believe that unless there is provision within the heating system to impose time control, the calculation base for all other measures is flawed and the projected savings cannot not be realised. The building regulations support this contention by recommending that timers be fitted to all boiler based systems. We recognise that operating times and temperatures of heating systems depend very much on occupant behaviour and that in-life operating times and temperatures are likely to deviate from the SAP assumptions, but it is important to recognise that unless householders are given the tools to automatically control the operating times of their systems they will not have the facility to readily match the assumed occupancy settings on which their Green Deal savings are predicted, nor to manage their system energy use efficiently.

Programmable room thermostats have the additional functionality of allowing different temperatures to be set for different times of the day. We have assumed a conservative efficiency improvement from the time/temperature programming function of 2.5% which is based on assumptions on reduced operating time and temperatures (equivalent to a quarter of the 10% assumed for turning your thermostat down one degree) and is validated by a US study carried out by Gas Networks to validate the impacts of programmable thermostats. This analysed the use of programmable thermostats in 7,000 properties and identified a reduced gas usage of 6.2% when this technology was installed.

24-hour or 7-day programmable room thermostats

To enhance further the opportunities to reduce energy consumption, the TACMA proposal for programmable thermostats, detailed in the accompanying spreadsheet, includes 24 hour versions that repeat the same programme each day and 7-day versions which allow consumers to select different time and temperature programmes for different days of the week. Most of the 7-day products can also be set to provide 5/2 day programming as per the underlying time profile embedded within SAP. As stated above, there is no facility within SAP to measure the impact of different time profiles, but a product programmed to provide both work-day and rest-day programme will, if used properly, deliver greater savings than a product that simply repeats the same programme each day of the week regardless of lifestyle pattern difference between work days and rest days. We have not assumed any energy savings from these but believe that improved functionality should be favoured.

Wired and Wireless options

To further reduce the disruption and possible damage to decor, TACMA strongly recommend the promotion of wireless based systems that eliminate field wiring and restrict electrical installation activity to the proximity of the boiler. Wireless thermostats are more expensive to acquire, but the additional cost can be offset against the speed of installation, the removal of the need for wiring runs in the property with the attendant risk of damage to décor and other property. For comparison, the TACMA proposal includes both wired and wireless based solutions, both types offering identical functionality in terms of energy performance and user interface. It is important to recognise that this type of low powered wireless device is a mature and robust technology which has been on the market for over a decade.

Energy saving claims; Thermostatic Radiator Valves (TRVs)

Savings figures for TRVs have been taken from the CERT spreadsheet, which comes from the Standard Assessment Procedure (SAP.)

These savings figures are very low despite significant evidence from mainland Europe showing savings from TRVs of 10% or more. However, because of differences in base system operational assumptions it is difficult to transfer this evidence to the UK at this stage so we have chosen to stick with the robust SAP data for this initial Green Deal call for evidence.

When TRVs are installed separate from a boiler installation the cost of draining down the system can make this a prohibitive measure in relation to the ‘golden rule.’ We have therefore analysed TRVs as a measure to be installed alongside cavity wall insulation. This merges the cost/savings potential of the two measures but also makes a logical sense as the TRVs will prevent overheating in the dwelling after the insulation is installed, thus ensuring that comfort levels are maintained and excessive heating in particular rooms as a consequence is avoided.

Additional data

Installation costs have been derived from information sourced from installers and published prices. These are detailed in the spreadsheet.

To convert carbon savings in the CERT spreadsheet to financial savings we have used a conversion factor of 0.203kg CO2 per kWh (DECC website) and an average UK residential gas price £0.041/kWh taken from the Biomass energy Centre (Gov.UK site).

Interest rate used in ‘golden rule’ calculations is 8% annual interest. Cost of loan calculation assumes constant interest rate and constant monthly repayment amount for duration of loan (Excel function PMT)

[1] Domestic energy consumption by end use 2008 DECC Energy statistics.

[2] Data from Energy Saving Trust, based on 350,000 completed Home Energy Checks in 2008/09. Percentages are against UK homes with gas or oil boilers, excluding back boilers (about 20m).

[3] MTP BNDH19 Evaluation of H e ating Controls, 2008

Prepared 22nd June 2011