Dr Sharn Enzinger

Reintroduction of Ceiling Insulation in the VEET scheme

Energy Policy and Programs

Department of Economic Development, Jobs, Transport and Resources

8 December 2015

Re: Reintroduction of Ceiling Insulation in the VEET scheme

Dear Dr Enzinger

The Energy Efficiency Council welcomes the opportunity to provide input on theproposed reintroduction of ceiling insulation in the Victorian Energy Efficiency Target (VEET) scheme.

The Council strongly supports the reintroduction of ceiling insulation into the VEET with appropriate mechanisms to address the quality and safety of products and installation. We note that when ceiling insulation was formerly supported by the VEET scheme there were appropriate controls in place and we are not aware of any major incidents.

Ceiling insulation is a safe product if it is appropriately installed. The deaths that were linked to the Commonwealth Government’s former Home Insulation Program were tragic and largely associated with non-compliance with safety standardsthat are relevant for other electrical products and building materials[1].

Furthermore, in addition to ceiling insulation lowering energy bills and greenhouse emissions, it also improves the thermal performance of homes. Improving the thermal comfort of Australian homes could play an important role in reducing the approximately 3,000 deaths each year that are associated with hot and cold periods.

A major global study published in the Lancet earlier this year[2] found that 6.5 per cent of deaths in Australia were associated with cold weather and 0.5 per cent with hot weather. In contrast, just 3.9 per cent of deaths Sweden were linked to cold weather, which means that around 1,200 cold-related deaths would be avoided each year in Australia if our mortality rates were similar to Sweden. While a number of factors may contribute to the difference in mortality rates, the thermal performance of homes likely plays a key role.

The Council supports the following recommendations from the KPMG Review of Ceiling Insulation and the Victorian Energy Efficiency Target:

  • The Essential Services Commission (ESC) should report to the Department on its performance in relation to approvals of products and accredited persons and compliance activities in relation to the activity of ceiling insulation.
  • Update the reference to Australian Standard AS3999-2015 in Schedule 11 of the VEET Regulations.
  • The ESC should ensure that its Audit and Compliance team has the appropriate resources and knowledge to undertake investigations to assess the compliance of ceiling insulation installation against scheme requirements.
  • Undertake risk-based spot inspections of the installation of ceiling insulation in the first year of its reintroduction to ensure that installers have completed the mandatory training and they are installing in accordance with relevant Australian Standards.

The Council has no comment at this time on the following recommendations from the KPMG Review, but looks forward to working with the ESC on these matters:

  • Deem insulation products which contain foil to be ineligible for approval under the VEET through an explicit statement in the VEET scheme documents.
  • Require the following mandatory training requirements for installers:
  • Worksafelyintheconstructionindustry(CPCCOHS1001A)
  • Worksafelyatheights(CPCCM2010B)
  • ApplyOHSrequirements,policiesandproceduresintheconstructionindustry (CPCCOHS2001A)
  • Installceilinginsulation(CPCCPB3027A)
  • Installbattinsulationproducts(CPCCPB3014A).

We congratulate the VictorianGovernment for its efforts to enhance the operation of the VEET. Please contact me should you require further information on any of the issues raised in this submission.

Yours sincerely

Rob Murray-Leach

Executive, Policy and Advocacy

1 | Page Suite 2, 490 Spencer Street, West Melbourne VIC 3205 ABRN 136 469 291 ABN 63 136 469 291

[1] The Royal Commission into the Home Insulation Program 2014 Report of the Royal Commission into the Home Insulation Program, Commonwealth of Australia, Canberra

[2]Gasparrini et al 2015 “Mortality risk attributable to high and low ambient temperature: a multicountry observational study” The Lancet Vol 386 No 9991