INSULATION COUNCIL OF AUSTRALIA AND NEW ZEALAND

Submission relating to the inclusion of ceiling insulation in the Victorian Energy Efficiency Target scheme

Thank you for the opportunity to provide comments on the VEET review paper on ceiling insulation.

We are very encouraged that ceiling insulation is making steady progress to being re-activated in VEET in the near future.

For households, ceiling insulation has the best and longest lasting cost/benefit impact on reducing fuel bills and increasing and maintaining comfort. A well-insulated home will also help protect health and well-being of its occupants. This is particularly valuable for low income families.

Generally we agree with the analysis and recommendations of the KPMG review. There are some points we would like to add.

  1. Whereas ICANZ was instrumental in the formation and trialling of the initial courses the current training program is now an insulation industry training program and covers far more products than glasswool batts. The first training program was conducted in November 2013. and since then has conducted 19 training courses across Victoria, NSW, South Australia, Queensland, Tasmania, Western Australia and the ACT. More are planned for 2016. 202 installers have been trained, 96 are from Victoria. The option is there for any particular insulation provider to add on a section covering unique features about the their particular insulation

At least 80% of the content of the course is general concentrating on correct installation practice, risk assessment and avoidance and the latest requirements of current Australia Standards. These are areas common to all forms of insulation.

  1. The training material is constantly reviewed and improved as a result of the feedback we receive from installers during the course. This feedback has been overwhelmingly positive in relation to what is currently presented. We have trained personnel from NSW Department of Environment and Heritage, the South East Councils Climate Change Authority and have a standing invitation to the staff of ACT Energy Efficiency Improvement Scheme. We would recommend any AP or VEET/ESC inspection staff for insulation undertake this training course.
  2. In section 2.4 – Program Design – of KPMG’s report under the section of proposed additional measures for ceiling insulation it lists the possibility of including a 100% post-installation inspection. ICANZ would query the need for such a heavy auditing regime and added cost for its inclusion. We note it is not included in KPMG’s list of recommendations. There is an additional check worth considering that is not covered in KPMG’s report. That is that installers provide a predetermined range of photos (date stamped and geolocated) with the finished job report. This would allow more accurate desk auditing and could be subject to random site auditing by inspectors. It would also reduce the risk of fraud. The awareness of this procedure could be part future installer training.
  1. KPMG have recommended dropping CPCCPB3015A, HLTFA201A and CPCCCM1015A for training requirements of VEET. Based on strong feedback we have received from installers that have completed the course we would recommend ESC reconsidering the re-inclusion of CPCCC1015A (Measurement and Calculations). This practical workshop takes around two hours of training time and provides the skills to order the right material and quantity for a job. By having these skills it is far less likely to under-order material and when caught short on site be tempted to leave out hard to get at areas of the ceiling.
  2. In relation to the version of the main Australian standard – AS 3999 – called up in VEET, there is a conflict between the Minister’s statement and the recommendation of KPMG. The Minister has identified the 2012 version of the Standard whereas

KPMG have recommended the current 2015 version. We, and any RTO, would always recommend using the latest published version.

We look forward to working with ESC and VEET personnel to address the remaining issues raised by KPMG in relation to re- activating ceiling insulation back into VEET in 2016.

Yours sincerely,

Dennis D'Arcy

ICANZ CEO

08 December 2015

About ICANZ. The membership of the Insulation Council of Australia and New Zealand (ICANZ) manufacture and supply approximately 70% of insulation used by the building industry. The Industry provides employment directly and indirectly to over 4000 people. All ICANZ members are affiliated internationally through their production technology and provide products that meet all required manufacturing and product standards.

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CEO – Dennis D’Arcy 159 Wellington Road Clayton Victoria 3168 Tel: (03) 9265 4000
Mob: 0418 392 382 / Secretary - Douglas Watson Associated Management Services L6, Suite 10, 365 Little Collins Street Melbourne VIC 3000 Tel: (03) 8637 4702