Windows Solar Gain in domestic buildings

La demande est partiellement réussie.

Dear Energy (ENER),

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:

Domestic dwelling windows solar gain is a significant contribution to the energy balance calculation used for the statutory Energy Performance Certificates, Building Regulations Compliance and the Digest of Energy Statistics for climate change. This contribution to the energy balance calculation is mandated for EU members by EN 13790:2008. It is anticipated that the validity of this windows solar gain contribution could only have been demonstrated by means of an iterative mathematical modelling study. Please provide visibility of the iterative mathematical modelling final study report, or visibility of the alternative approach adopted.

This is needed to support my research.

Yours faithfully,

Charles S Murphy

Dear Energy,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Energy's handling of my FOI request 'Windows Solar Gain in domestic buildings'.

My original FOI request was submitted on 24th December 2014 and its answer is long overdue.

A full history of my FOI request and all correspondence is available on the Internet at this address: http://www.asktheeu.org/en/request/windo...

Yours faithfully,

Charles S Murphy

Dear Mr Murphy,

Thank you for your request for access to documents.
Unfortunately you have not indicated your postal address that is required for registering and handling your request in line with the procedural requirements. Please send us your full postal address at your earliest convenience. Pending your reply, we reserve the right to refuse the registration of your request.

You may, of course, use directly the electronic form for entering your request:

http://ec.europa.eu/transparency/regdoc/...

Please apologize for our delay in answering your original application.

Best regards,

ENER ACCES DOCUMENTS Team
European Commission
DG ENER
Unit A.1

DM24 08/046
B-1049 Brussels/Belgium
+32 2 298 17 47

Afficher les sections citées

Dear Energy,

As requested my postal address is [postal address]

My email address is [email address]

I would prefer to communicate by email

Yours faithfully,

Charles S Murphy

Énergie

Dear Mr Murphy,

In relation to your request on the windows solar gain and the visibility of study report or alternative approach adopted, find below the study website from where you can download the just finalised draft final reports related to the ecodesign preparatory study on window products:

http://www.ecodesign-windows.eu/document...

Please do not hesitate to contact us for further information.

Best regards,

ENER ACCES DOCUMENTS Team
European Commission
DG ENER
Unit A.1

DM24 08/046
B-1049 Brussels/Belgium
+32 2 298 17 47

Afficher les sections citées

Charles S Murphy

Dear Energy,

The energy balance section of the document assumes that the shutters are all-open or all-closed and ignores the dominant occupier actions making the result invalid.

Yours faithfully,

Charles S Murphy

Charles S Murphy

Dear Energy,

This note supersedes that submitted by me on 6th March 2015.

These comments only cover windows solar gain aspects of Task 4, Lot 32, Ecodesign Preparatory Study on Windows Products, Annex A

The results are expressed for two cases, shutters are 'all-open' or 'all-closed' and unrealistically ignores the dominant occupier actions. Does the document generally include 'blinds' within the description of 'shutters'? Are they assumed to be 'all-open' or 'all-closed' throughout the whole day and year? If not, what are the assumptions? This aspect is important because when they are closed, windows solar gain is almost zero, when they are open windows solar gain is unrestricted and when the occupier actions are recognised the windows solar gain will be very small.

How does the model deal with the situation when the solar gain is sufficient to heat the room above the desired temperature? This question applies to both summer and winter.
1. Does it calculate the cooling energy to reduce the temperature and include this in the overall energy performance?
2. Does it record the excess temperature?
3. Does it calculate the proportion of the excess energy that can be stored within the thermal mass?
4. For the winter situation, how does it take account of the fact that the excess energy must be stored by the thermal mass within the daylight period and all released during the next night period? If it is not taken into account, the energy stored within the thermal mass will saturate.
Is the energy performance calculation integrated over the whole year?

Does the model take account of the fact that many homes do not have air conditioning systems to distribute the excess windows solar gain energy?

What is the definition of a 'Real Window' and a 'Adiabatic Window'?

Does the model assume any other attenuation of windows solar gain other than that by the shutters?

Figure A–58 has an typographical error, all the cases are shown as 'without shutter'.

Figures A-57, A-58 and A-59 the colours are not distinctly different.

Yours faithfully,

Charles S Murphy

Dear Mr Murphy,

We acknowledge reception of your remarks and questions. These would need to be addressed directly to the consultant in charge of the preparatory study on windows.
Indeed, the process for developing an Ecodesign/Energy Labelling measure consists of several consultative steps. The first one being the preparatory study, carried out for the European Commission, by an external contractor. Between other tasks, the contractor sets up a website which shows the different versions of the preparatory study and which facilitates exchanges with stakeholders.
Therefore, we invite you to register and address your remarks and questions via: http://www.ecodesign-windows.eu/register...

We thank you for your active participation.

Best regards, Energy Efficiency of Products Sector

Afficher les sections citées

Charles S Murphy

Dear Energy,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Energy's handling of my FOI request 'Windows Solar Gain in domestic buildings'.

A full history of my FOI request and all correspondence is available on the Internet at this address: http://www.asktheeu.org/en/request/windo...

Yours faithfully,

Charles S Murphy

Dear Mr Murphy,

We do not understand what you mean by passing your request to the person who conducts freedom of information reviews.
In our view, we replied to your request for access to documents along the provisions laid down in Regulation (EC) 1049/2001.

We are of course available for further clarifications, if you have any follow-up questions on our reply.

Best regards,

ENER ACCES DOCUMENTS Team
European Commission
DG ENER
Unit A.1

Afficher les sections citées

Charles S Murphy

Dear Energy,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Energy's handling of my FOI request 'Windows Solar Gain in domestic buildings'.

Popular opinion within the building science community suggests that solar energy admitted through the windows in a building saves a significant amount of fuel. This belief is reflected in most national and international documents enabling governments to dishonestly claim that domestic building Greenhouse Gas emission are 26% lower than actuality. The basis for this false claim is that energy assessments for the winter assume that none of the the windows solar energy is attenuated by blinds or shutters, and this is obviously not true. The energy assessment for the summer assume that the blinds or shutters are fully closed, providing 100% attenuation, enabling the dishonest claim that the building will not overheat, or consume considerable cooling energy. These two energy assessment assumptions are clearly not valid and significantly distort the actual energy performance of windows.

A full history of my FOI request and all correspondence is available on the Internet at this address: http://www.asktheeu.org/en/request/windo...

Yours faithfully,

Charles S Murphy