Please see below the submission from CSR Bradford.
CSR Bradford welcomes the opportunity for ceiling insulation to be considered in the VEET program as we believe it is the most cost effective way a home can improve its energy efficiency. This is supported by many government agencies including Sustainability Victoria. We have reviewed the KPMG report and are supportive of most of its recommendations and the approach taken. We would like to make the following comments in relation to the report:
· We are supportive of the need for insulation installers to be trained. CSR Bradford has worked closely with our industry to establish the program run by AWCI and ICANZ. To date we have had over 100 Bradford installers undertake this training and this process will continue into 2016.
· Section 2.4 of the report deals with post-installation inspections. We are interested in learning more about how the inspectors will be registered (what criteria do they need to meet).
· Section 2.5, we feel that the governance of the program would be improved if it was mandatory that installers take photos of each project they undertake. We note that this is a requirement of installers in the solar PV industry who want to claim rebates (STC’s).
· Section 2.6 – although mention is made that installation must comply with AS3999, it should be made clear that this should be the latest 2015 version. Further, given the requirement in this standard (and also AS3000) for older homes to undergo an electrical inspection prior to installation, we feel it would be better to make this mandatory for all homes participating in the program – not just older ones that (may) have wiring from pre 1986. This would address one of the key risks identified in the Royal Commission into the Home Insulation Program.
We trust that these comments will help the Department in your review. If anything is unclear or if you require anything further please do not hesitate to contact the undersigned.
Yours sincerely,
Peter Ruz
Peter Ruz | National Marketing Manager | CSR Bradford
T +61 2 9964 1727 | M +61 409 342 112 | F +61 2 8362 9003 |
Level 5, Triniti 3, 39 Delhi Road, North Ryde NSW 2113