Energy Bill

Memorandum submitted by Danfoss (EN 32)


1. Danfoss manufacture central heating controls including timers, thermostats, and thermostatic radiator valves. These products are mainly used in the residential buildings market

2. Danfoss also manufacture heat-pumps and are leaders in the field of automatic controls for district heating and cooling

3. The company are actively involved in relevant trade bodies including TACMA which represents the residential heating controls industry in the UK. Danfoss recognise the important role of a competent and focused trade body

4. Danfoss welcome the opportunity to submit evidence to the Public Bills Committee enquire into the Energy bill and are available to provide further supporting evidence should this be required

Executive Summary

5. Green Deal should as a high level objective attempt to tackle the 8 million homes that are not equipped with a room thermostats, this would deliver an average saving per household of 1500kWh/annum

6. Green Deal as well as promoting heating controls measures in their own right, should consider the holistic benefits of making controls measures a mandatory part of any Green Deal measures that impacts on the energy balance of the building

7. As well as delivering improved building energy performance to owners and tenants, Green Deal controls measures are likely to generate significant job opportunities in the manufacturing sector, service sector and installation sector, many of the latter falling into the SME category

The case for controls

8. The prime function of heating controls is to match the level of heat generated by the boiler, (or other types of heat generator), to the prevailing and ever changing heat demand of the building in which they are installed

9. Simple controls such as timers and room thermostats provide the user with a mechanism for determining both the operating period of the system and the desired internal temperature of the building. Putting householders in control. Turning the thermostat down by just 1C will reduce energy consumption by up to 10% (source Energy Saving Trust, EST)

10. Simple heating controls are a viable and low cost standalone measure. For example at a cost of around £200, a room thermostat can be installed with a payback period of 2-3 years for a typical semi-detached home.

11. The most numerically significant and easy to deploy controls measures fully meet the requirements of the Green Deal Golden Rules as standalone measures, See annexe I for further information on costs and savings

12. As part of a more holistic approach, in order to improve system efficiency, reduce the potential for energy waste and to prevent overheating, heating controls measures also need to be considered at the same time as other measures:

o If the expected savings from building fabric measures including wall insulation, draft proofing and high performance windows are to be realised. All such measures reduce the heat loss from the building but do not dynamically reduce the heat output from the heating system to match lower heat losses from the improved building fabric. Uncontrolled overheating by just 1C will increase the heating costs by up to 10% and reduce the viability of the building fabric measure

o In situations where high efficiency boilers or heat-pumps replace older less efficient appliances if the full benefit of these expensive appliances are to be realised

o The latter point is recognised and dealt with within Part L of the Building Regulations, but there is no such recognition of the need for controls measures associated with the mentioned building fabric improvements, for exam[le, in CERT, despite the considerable opportunity for conservation of power

13. The essential benefits of heating controls are recognised by policy makers and compliance requirements, including room thermostats, are clearly described within the DLCG Domestic Buildings Compliance Guide, however SAP, the Governments assessment tool, lacks the resolution to accurately score the full impact of controls measures. Despite this, SAP based assumptions used within the OFGEM CERT scheme still clearly indicate that selected heating controls measures can deliver worthwhile and viable savings

14. A recent study by TACMA, using EST data, clearly shows that around 40% of homes in the UK, (approx. 8 million), do not have a room thermostat. This is a substantial energy efficiency improvement opportunity, bearing in mind that each home, based on CERT data, could reduce its energy consumption by around 1500kwh/annum. See annexe II for more evidence of the scale of poorly controlled heating systems in the UK housing stock

15. Given the relatively poor state of the heating controls fit in much of UK housing it becomes obvious that controls as a standalone measure are essential in their own right if the nation is to reduce its space heating energy consumption and help alleviate fuel poverty. Green Deal could provide the delivery vehicle to substantially upgrade the installed base of heating systems

16. There is a recognition that some standalone controls measures, for example the fitting of thermostatic radiator valves do not pass the golden rule test, Industry would argue to a large degree this is a result of the treatment such products get from SAP and in turn CERT, none the less, Part L of the Building Regulations recognises the importance of such products and other zoning solutions and it would therefore appear contradictory not to try to accommodate their inclusion into one or other Green Deal measure, perhaps the solution is a bundled measure comprising

17. for example thermostatic radiator valve together with an insulation measure where the sum of the two pass the Golden rule

18. Controls are also the key to ensuring that other measures deliver the projected saving. Only by dynamically matching heat supply to heat demand can fabric improvement measures be guaranteed to save energy and promised return on investment

The role of controls in the Green Deal

19. The Green Deal is a hugely important initiative which, as well as offering substantial environmental and energy efficiency benefits, also offers the opportunity to embark on a major national building renovation scheme which will benefit owners, owner occupiers and tenants alike. It will also deliver substantial employment opportunities to a wide cross section of businesses, including SMEs and contribute to the economic recovery that the country strives for

20. A Key success factor for the Green Deal is that it must deliver the promised savings, to do that each measure must deliver to the limit. Savings must not be compromised by lack of vision of the consequences of not recognising the interdependence of building fabric improvements and the need to dynamically match this heating system output. This dependence can only be managed by heating controls.

21. Danfoss believe that the government should consider mandatory controls measures whenever building fabric measures or heat generator/renewable measures are installed under Green Deal. As well as ensuring that a balance is maintained between heat demand and heat generated, this would have the added advantage of tackling the significant number of inadequately controlled heating systems and for nominal additional costs across the lifetime of building fabric measure would raise the heating controls standard of all Green Deal treated properties to the level required in the current building regulations. A truly once in thirty year opportunity, given the renovation cycle for building fabric measures

June 2011

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

Annexe I – Projected costs and savings for sample heating controls measures

Source: Danfoss

Annexe II– Overview of UK housing stock, Heating controls opportunities

Prepared 22nd June 2011