I have a quick question relating to obscure glass, as Pilks have a 1-5 rating for each obscure glass in the range , I would assume that there are at least 5 different 'ranges' of solar transmission through them . Does this mean that a different rating certificate is required for each obscuration range of obscure glass? or if exchangeability, as you put it, is not allowed then every optional obscure glass will need to have a WER certificate to ensure that bathroom windows comply to the regs .

For years we sealed unit manufacturers have been raising the standards when it comes to energy efficiency, we have been audited and tested for the quality system and the actual products that we fabricate, all at our own cost. During this time frame manufacturers have had it relatively easy with no compulsory testing of actual frames from the production lines and it seems that this situation will continue with the introduction of WER's allowing the frame companies to test 'virtual' frames by way of simulation using figures supplied to them by their profile manufacturers and the IA's checking only the laid down procedures (regardless of actual product compliance or quality)
I have heard so many times how lucky us sealed unit guys are to have whole frame compliance brought in, because we would not be able to achieve a good enough centre pane U value on our units to continue as before, so I wonder, what will happen to this redundant U value when gaining a WER? (will it fall off during simulation?) No it will still be there and measurable and the lower it is the better the rating.
Changing the method of measuring energy efficiency does not increase it and in this case it will muddy the waters so much it will conceal the inadequacies of the system of frame compliance.
We are starting to see a few variants on the scheme of issuing WER labels, ie Manufacturers licenses, Installer licenses, Installer licenses with the installer name on the label and a few others to come, all extra revenue streams and soon more will surely come out with the frequency of Windows XP security updates.
If, in the future, the GGF thru their revenue generating arms (BFRC, FENSA) impose any extra charge for substituting like for like sealed units in the WER scheme,that will tell you that the GGF does not and did not recognise th EN1279 standards because if they did they would be confident that the sealed units supplied would be up to spec, whatever that spec comprises.
Some larger sealed unit manufacturers have got contracts to supply units that have been tested in frame but are not too vocal at present, that could change when their customers start to shop around.
Sealed unit manufacturers need to ask themselves who the GGF represent because they are not your voice in the industry anymore, they recommended their own company's (BFRC) rating scheme to the government to benefit from the extra cash this would generate for themselves. There were other options available!.
I can see the need for a new IGU association, if Paul gets the ball rolling I would join.
I have been told that around 1400 small firms like mine could be facing closure if the proposed system comes into force, so the next stop is our local MP, he needs to know that we have been misrepresented and placed in jeapordy by a supposedly 'non profit' organisation with a hidden agenda.

Just spoken to Toby at BFRC after leaving a couple of messages for a return call, and waited 3 weeks.

I explained my concerns regarding loosing sealed unit business to the large frame companies. He said, i wish i could tell you that everything will be fine, but i cant. He says to look out for the press release end of March-April which will out line any changes. Not much else we can do i suppose, just continue to loose business.

My issue has always been to the fact that the WER is indicative of the window/glass configuration of an adopted average window and bears no relationship to the actual window being sold and installed. Although it gives the purchaser an idea of how well it compares with another type of window/glass system it fails to provide them in most cases with a window that actually achieves this rating.

To label a window and display a value for “Energy Index KWH/perM2/per year” and then qualify it by saying that this depends on location, climate, building type, design and size, is like going into "Currys" picking out an "A-rated" fridge and then being told that in fact its rating is actually based on one half the size and will only perform at that level if kept in a cool room and the door is never opened.

It is understood that due to variables in window sizes and styles that even an "A" rated window system, which is supposed to be energy neutral (0kwh), or in some cases even energy positive (+5kwh), will in many cases be energy negative, particularly with complex window designs that include smaller glass panes and several opening vents.

Moreover the fact that the difference between an A & C rating could be as little as 10 KWH/perM2/per year, how can a potential saving of less than £3 per year, at current energy prices based upon that "average window" justify to the customer the extra cost associated with the moving from a C to an A rating, unless of course we are selling on the "green" ticket and then we shouldn’t be basing it on an average window at all but show the customer an accurate figure base upon the actual window they are buying.

A system designed to encourage the purchaser to buy "green" should at least be set up to reflect the actual calculated energy rating of the window being installed rather than the one that is very different in design and size. Perhaps then window styles would change to in order to take further advantage of improvements in better insulation.

Moving to the question concerning the inflexibility of a system where products cannot be substituted even when it can be shown that this is for improvement. Are we really to understand that an energy rating given for a window that is calculated with standard float glass cannot be sold with a low iron glass even though this is clearly going to improve its performance. The same applies to spacer bar, where aluminium is substituted with warm edge. Are we asked to believe that this would mean that the window no longer has at least the same rating as before the improved materials were used.

Even more baffling is the case for substituting glass from different manufactures since manufacturers have been known to exchange glass with each other and rebrand it as their own. Look at the two leading brands of Low Iron glass, their properties are identical, the figures for two leading soft coat low e glasses are identical.

I think we should immediately rethink the system of displaying a value for "Energy Index KWH/perM2/per year" as it means nothing in respect of the actual window being sold and that if we are to work on the basis of adopting the average window as a benchmark then this should allow for flexibility.

Providing that values for substituted components are the same or improved and as long as no change in the rating band is inferred then this should be acceptable.

As long as a "C" remains a "C" what’s the issue.

I have been reading with great interest all the comments made by various people in the industry, regarding their feelings on the proposed WER/BFRC system.
Being part of the working party looking into this system, and all the problems with the system raised by various people, for example costs, rules for system, IA audits, how new products reach the market, checks on whether companies are sticking to the rules(that no-one has seen) etc, which have been raised with the GGF/BFRC and have either been dismissed or never replied to.
Looking at the BFRC/WER system overall and how it works; The window manufacturer calls in a testing company approved by the BFRC to simulate their window and IG units. The customer has to decide on the amount of licences he requires, this normally ends up being two on average, but both licences have the same IG unit make up, so as to help save on the cost of licences and restricting his customers from buying the IG units from a different supplier therefore increasing his profits. The thermal efficiency of the frame is arrived at by testing just the profile, disregarding any hardware, air equalisation holes, drainage slots, which are incorporated in the window during manufature. As these results come from the profile manufactureres themselves, what checks are being done on fabrications, to make sure that there fabrication is being carried out to the test results, other than just testing the best bits of their product. This is then left to the IG unit industry to come up with even better performing units, to compensate for some of the poor performing window systems available.
When it comes to testing the components making up an IG unit, every conceivable part is broken down and tested individually, to come up with a thermally efficient result, which then added to the window result reaches either a rating of A/B or C. If this does not reach an A, as most system suppliers demand, the IG unit is adjusted in various combinations so as to reach an A. This is where the problems are being caused for the IG unit industry. The BFRC are making everything so specific. They are telling us what components can be used for example the type of hot-melt, but if the hot-melt supplier was declared bankrupt and you want to change supplier, or if your delivery was delayed, you are not allowed to substitute the component until new test result labels are attained.
The generic problem with the system, as I see it, is the BFRC in their wisdom have made A/B and C bands far to close together, allowing people to tweak their components to just get into the next band up. Having a system operating in this way, causes its own problems for the IG industry. If I have 20 customers all using different components, where do I store these? How do I make sure every customers units are made using their correct specification? How do I negotiate products selling or buying, when I cant go anywhere except do as I'm told, or loose everything?
The bands should have been made wider apart, allowing the BFRC/WER system to allow substitutions for products. For example- all warm edge spacer to meet an A specification. This would allow IG manufacturers to offer an equally rated unit to their customers, keeping alive free trade, and allowing new products to come onto the market, improving the products we manufacture, which to my mind is what the government are asking the industry to carry out. They are not asking for a system where the window manufacturer holds all the cards.
Hopefully this will give you a quick insight on how I see things after a year on the working party. If you would like to discuss anything further, you can contact me on 0208 648 1122.