Just when you think that you’ve got a handle on everything, you can guarantee that something will come from left field that was completely unexpected. I really should expect the arrival of unknown unknowns (© Donald Rumsfeld, US Secretary of Defense, 2002). Nobody spotted the next thing that has been thrown at us which came from the European Commission DG Environment via our very own Defra. Two documents landed in my inbox for comment – “Technical Specifications for Green Public Procurement – Windows Background Report” and “Windows, Glazed doors and Skylights – Green Public Procurement Product Sheet”. The background report is thirty pages long and the Product Sheet eleven pages long. These count as short documents compared to the current norm of documents of over one hundred pages but still circulated for comment during the peak summer holiday period. By the time you read this, the comment period will be over but you can still see what you missed by downloading them from www.pauljervis.net.

This focus on windows is part of a process which has escaped the attentions of anyone I know . Specifications for Green Public Procurement have already been developed for eleven products (don’t ask me what these are, the papers don’t say) and windows are now in the next group of ten products (again, I don’t what the rest are).

The Background Report has a lot of very basic stuff about windows, for example  “Windows are composed of two basic sections: the glass used for the main body of the window, and the frame used to mount the glass and secure the structure into the building envelope“. Wow! There’s also a strange mix of European and US terminology. PVC-U frames are referred to as “vinyl” frames sometimes which is the American term. In fact, I get the impression that the document has been prepared not by a window expert but by a consultant who has based his work on researching American literature. To confuse matters more, there are references to UK specific papers.

They seem to be speaking to someone who has never seen a window before and leading them step by step from the very basic up to current latest technology, even technology that doesn’t exist! It claims that a sealed unit with what it terms a low-emittance coating, what we know as low emissivity, achieves a U value of 0.27. According to Wikipedia the thermal emittance of a material refers to its ability to release absorbed heat. It is usually expressed as a number between 0 and 1. Of course, we know that the quoted U value is wrong. It gets worse. It has obviously been written by someone who is anti everything except timber for windows and looks like a quote from Greenpeace circa mid-nineties. It ignores all the evidence, including the report prepared for the EU by PE Europe which reports that there is no overall winner in materials for window frames and that design is the most important factor. The Green Guide to Specification also recognises this (“The main environmental impact of windows is from the heat loss through them”), but when you’ve got your hobby horse, then you ride it all day long with not even a passing nod at reality.

I could go on but there are just too many oddities, errors and omissions to cover in one short article (my comments of the documents run to 5 pages so far). There is also, perhaps surprisingly, a lot of accurate information within them. It makes me wonder whether it was written by more than person or whether it was a cut and paste exercise. It contradicts itself. For example, in one paragraph it claims the life of an aluminium window is 15-20 years and elsewhere as 20-35 years. My guess would be that this has been contracted out to a private organisation that does not have the current technical knowledge and who have used the internet to get this rag bag of biased, wrong and outdated (mis)information.

 If you need a headache, read them for yourself.

As it takes in various labelling systems from around the world, it also includes a long section on BFRC and Window Energy Ratings so if Public Procurers latch onto this document, you can bet your hat that specifications will increasingly require higher WER ratings. Can it be long before all fabricators and installers will be rated? Is this a good thing or just another badge which means little in the real world?  I think that is for another day. The paper recommends that the BFRC scheme be extended across Europe when, in fact, the BFRC scheme is the result of a European initiative some years ago and is therefore available to all Member States now. (Just one sign that the author’s are not knowledgeable or up to date in our industry).

The windows product sheet refers to two sets of purchasing criteria :

Core criteria - suitable for use by any Purchasing Officer across the Member States and which address the key environmental impacts. They are designed to be used with minimum additional verification effort or cost increases. For instance the maximum U values are higher than the comprehensive criteria (2.0 versus 1.5) and other requirements are lesser, a sort of comprehensive-lite.

Comprehensive criteria – suitable for those who wish to purchase the best environmental products available on the market. These may require additional verification effort or a slight increase in cost compared to other products with the same functionality.

Verification is demonstrated in a number of ways with the Nordic Swan ecolabel being heavily identified as the main way. This is a new one on me and I had to look on the internet to find out more about it (http://www.svanen.nu/Default.aspx?tabName=StartPage). Perhaps the author’s on commission. No mention of the Green Guide, no mention of the Timber Window Accreditation Scheme and no mention of any other suitable labels that may be around.

At the end of studying these two documents, with their mixture of US, European and UK references, I was totally confused. I don’t understand the need for them in the UK. We have the Code for Sustainable Homes supported by the Green Guide which is itself a very comprehensive Life Cycle Analysis into which we have put so much time, effort and money. The Code requires improving thermal performance towards zero carbon in 2016. We have Window Energy Ratings which identify the over all energy performance of windows (and doors soon, probably)

It is strongly expected that we will have a similar Code for non-dwellings soon and one for existing dwellings has been proposed. What more do public procurers in the UK need?

I don’t know what the future is for these two rambling, confused and plainly wrong documents. Perhaps they will just be used in other Member States and we can rely on our tried and tested Green Guide and Code for Sustainable Homes, or will that be seen as a barrier to trade and therefore illegal? How about promoting the Green Guide or similar throughout Europe? How about some common sense?

Roll on retirement so I can put all this nonsense behind me.