Contents

1 Introduction

2 Background

3 VEET Ceiling Insulation program enhancements

3.1 Service Provider Accreditation

3.2 Installation Practices

3.3 Post-Installation Inspections

3.4 ESC Auditing and Compliance

3.5 Breaches of Electricity Safety

4 Additional measures

5 Other Issues

6 Consultation questions

Appendix A – ESC Ceiling Insulation Compliance Process Flow Chart (Draft)

Appendix B – Futura Consulting, Ceiling Insulation Due Diligence Review

1 Introduction

The former Department of Primary Industries (DPI) is consulted on measures proposed and measures introduced under the Victorian Energy Efficiency Target (VEET) scheme to mitigate risks to consumers and to the integrity of the scheme from the possible reintroduction of installing ceiling insulation under VEET.

When the VEET scheme commenced on 1 January 2009, the installation of ceiling insulation was prescribed to be an activity in respect of which certificates could be created. However, following the announcement of Federal rebates for installing insulation under the Commonwealth Government's Home Insulation Program (HIP), ceiling insulation was effectively withdrawn from the VEET scheme on 27 July 2009 by a discount factor declared by the then Minister for Energy and Resources that reduced the number of certificates that could be created for ceiling insulation activities to zero.

The discount factor declared on 27 July 2009 was due to expire on 31 December 2011. Prior to the expiry of the discount factor, and in light of residual concerns arising from ceiling insulation under the HIP and the uncertainty that created in respect of the level of greenhouse gas emissions savings that could be achieved through ceiling insulation under VEET, the Minister for Energy and Resources decided to extend the suspension of ceiling insulation under VEET by declaring a new discount factor.

To facilitate consultation on the possible reintroduction of ceiling insulation under VEET, section 3 of this issues paper sets out the measures that have been put in place to protect the safety of the public and the integrity of the scheme. In summary, the measures include:

  • specification of mandatory installer training requirements;
  • adoption of the latest revisions to the bulk insulation installation standard AS 3999;
  • introduction of post-installation inspection requirements;
  • enhancements to the scheme administrator's audit and compliance powers; and
  • establishing a new offence prohibiting building works that make an electrical installation unsafe.

In addition, to ensure that relevant lessons from the HIP have been addressed in the measures adopted in VEET, the former DPI engaged Futura Consulting to undertake an independent assessment of the measures put in place. The assessment generally supports the reintroduction of ceiling insulation under VEET and makes four recommendations for further enhancements to address identified safety risks. Futura Consulting also makes a further four recommendations on additional non-risk related matters. The outcomes of Futura Consulting's assessment are outlined in section 4.

Section 5 of this paper addresses other issues that have been raised with the former DPI in previous consultations concerning the inclusion of ceiling insulation under VEET.

Stakeholders are invited to make submissions on any of the other matters contained in this Issues Paper. In particular, stakeholders are referred to the consultation questions set out in section 6 of this issues paper.

2 Background

The VEET scheme, also referred to as the Energy Saver Incentive (ESI) scheme, is a Victorian Government legislative scheme designed to reduce greenhouse gas emissions by encouraging improvements in energy efficiency.

The scheme is established under the Victorian Energy Efficiency Target Act 2007 (the Act), and supported by the Victorian Energy Efficiency Target Regulations 2008 (the Regulations) which among other things, prescribes details of the activities that may be undertaken under the scheme to create certificates and the manner in which the number of certificates associated with an activity are calculated.

The scheme is administered by the Essential Services Commission (ESC) whose regulatory powers in respect of the scheme are set out under the Act.

The scheme operates by establishing annual targets for greenhouse gas emissions reductions and imposing obligations on certain energy retailers to contribute to meet the overall target by acquiring Victorian Energy Efficiency Certificates (VEECs) and surrendering those VEECs to the ESC. Retailers that do not meet their VEEC obligations are subject to a shortfall penalty calculated on the number of VEECs that the retailer was short of their liability.

Businesses accredited to participate in the scheme (accredited persons or "APs") may create VEECs for each tonne of carbon dioxide equivalent of lifetime greenhouse gas emissions saved from undertaking an energy efficiency activity prescribed in the Regulations (a prescribed activity).

3 VEET Ceiling Insulation program enhancements

Two key reports into the HIP, undertaken by Allan Hawke and the Commonwealth Auditor-General, identified the following as key issues regarding the HIP:

  • pressure for rapid program delivery and roll-out of insulation in support of economic stimulus aims with greenhouse emissions savings only a secondary aim;
  • under-resourcing of the program's administration - resulting in inadequate management oversight; and
  • inadequate audit and compliance programs at the commencement of the scheme.

In contrast, the objects of the VEET scheme are confined to the delivery of reductions in greenhouse gas emissions through the promotion of improvements in energy efficiency and the promotion of investment, employment and development in energy efficiency industries. The scheme is designed to be a market based scheme that encourages participants to deliver abatement at the lowest cost. As such, the speed at which energy efficiency activities are rolled out under VEET is affected by supply and demand for a range of energy efficiency products and services. To date, the scheme has been dominated by the installation of low cost energy efficiency upgrades such as the installation of energy efficient light globes, low flow shower heads and standby power controllers.

The scheme is now into its fourth year of operation and subject to the administrative and regulatory oversight of the ESC. In addition to being the scheme administrator for VEET, the ESC's non-VEET regulatory functions includes regulation of Victoria's electricity and gas supply sectors under the Electricity Industry Act 2001 and Gas Industry Act 2000.

Drawing from the outcomes of the reports into the HIP, the key risks to the administration of incentives for ceiling insulation under VEET are considered to be:

  • fire and electrical safety risks arising from the improper installation of ceiling insulation;
  • OH&S risk to installers from failing to follow appropriate OHS practices requirements and hazard identification processes; and
  • rorting risks.

Recognising that there are areas for improvement in the administration of ceiling insulation incentives under VEET, the former DPI in collaboration with the ESC has implemented a series of measures to enhance safety and compliance under the VEET scheme.

The measures, explained in more detail below address:

  1. service provider accreditation – including installer training and product approval;
  2. installation practices;
  3. post-installation inspections;
  4. ESC auditing and compliance; and
  5. breaches of electrical safety.

3.1 Service Provider Accreditation

A draft process flow chart showing each of the major steps outlined in this section is set out in Appendix A.

Installer Training

Since 1 July 2011, following consultations undertaken by the ESC, the ESC has had in place mandatory safety training requirements for all installers of lighting, shower roses, weather sealing, external windows and insulation products. These requirements are established as conditions of an AP's accreditation under clause 5.4 of the ESC Guidelines and detailed in Table2 of the ESC's "Explanatory Note – Guide to VEET accreditation".

For APs participating in installing ceiling insulation as a VEET activity, APs must complete and submit an Application for Additional Activities form to the ESC. Once accredited, APs must, via an online portal, provide a list of installers who have completed the mandatory safety training with information about which of the eligible units of competencies the installers have completed. The units of competency specified by the ESC for ceiling insulation installers are:

Unit

Description

CPCC OHS2001A
CPCPCM2003A

Apply OHS Requirements, Policies & Procedures in the Construction Industry; OR

Carry Out OHS Requirements;

CPCCCM1006A Work Safely at Heights;
CPCCPB3014A Install Batt Insulation Products (this unit of competency specifies the outcomes required to install thermal and acoustic insulation products to comply with manufacturer and job specifications); OR
CPCCPB3027 Install Ceiling Installation (this unit of competency specifies the outcomes required to install ceiling insulation to comply with safety requirements as well as environmental requirements for energy efficiency ratings in accordance with sustainable building practices, inc. identifying and complying with applicable legislative requirements, planning and preparing for work, installing ceiling insulation, and completing installation and post-work clean-up activities).

When APs apply to the ESC to create VEECs for installing ceiling insulation, APs will be required to include the name of the installer who completed the installation on the application form. Applications to create and register VEECs are cross-checked by the ESC to confirm that the installer who conducted the installation is listed as having completed the required training. If the installer is not listed as having completed the required training, the AP's request to create and register the VEECs associated with that installation will be refused.

Consistent with its general approach to verifying that installers who are listed by APs as having completed training have in fact done so, the ESC will undertake spot audits to confirm completion of the training with the training provider. The ESC will focus strongly on audit checks of ceiling insulation installers' training certification on the basis that ceiling insulation is, from an audit point of view, a 'high risk' activity.

Product approval

Under the Regulations, ceiling insulation products installed under the scheme must, in accordance with regulation 6(2)(a) and the criteria specified in Schedule 11:

"comply with the performance requirements of AS/NZS 4859.1:2002 (insulation material) and achieves a minimum winter R-value of 3.5 when measured and labelled in accordance with AS/NZS 4859.1:2002".

However, unlike the Minimum Energy Performance Standards (MEPS) program administered in Victoria by Energy Safe Victoria which provides a publicly accessible register of all MEPS registered products and their performance, there is no equivalent independent register for ceiling insulation materials.

In the absence of an independent authoritative insulation product register, APs are required by the ESC to submit an 'Application for VEET Approval of Product' form to the ESC along with evidence, normally in the form of test reports from a National Association of Testing Authorities, Australia (NATA) accredited or NATA recognised laboratory, to support the claim that their product meets these requirements.

Only products that have been submitted for approval and can demonstrate that they comply with the requirements of the Regulations may be installed to create VEECs. In the event that non-approved products are found to have been installed, or approved products are later found through an audit to not comply with the product eligibility requirements prescribed in the Regulations, the ESC may undertake compliance actions against the AP concerned. Compliance actions can range from warnings or reprimands, suspension or revocation of accreditation to prosecution in relation to offences set out in the Act.

Compliance meeting

APs wishing to engage in the insulation activity will be required to meet with the ESC Compliance team before they begin undertaking the activity. The purpose of this meeting is to ensure that the AP has the proper processes and procedures in place to meet their obligations under the Act and Regulations. If the Compliance team is satisfied with the procedures that the AP has in place, the AP will be permitted to participate in the activity.

If an AP's processes and procedures are not adequate for the activities the AP wishes to undertake, then the ESC Compliance team make suggestions and recommendations to enable the AP to be compliant with the Act and Regulations.

3.2 Installation Practices

The installation of bulk insulation is governed by Australian Standard AS 3999-1992 Thermal insulation of dwellings – Bulk insulation – Installation requirements. In response to safety concerns relating to the risk of fire from the incorrect installation of ceiling insulation around recessed down lights, the electrical wiring rules AS/NZS 3000:2007 were revised to include clarifications around the minimum clearances required around down lights and certain types of old electrical wiring.

Standards Australia also conducted a review of AS 3999–1992 and identified the need to include amendments addressing:

  • clearances around recessed down lights;
  • clearances around other heat generating equipment;
  • the installation of barriers or guards to maintain the minimum separation between insulation materials and down lights;
  • pre-installation safety and OHS risk assessments;
  • installation practices concerning electrical safety risks.

A revised version of AS 3999-1992 incorporating these amendments was published in March 2012. These revisions have also been adopted for the purposes of VEET by amendments1 to the Regulations specifying that ceiling insulation installations must comply with the revised standard.

3.3 Post-Installation Inspections

On 1 January 2012, a package of amendments to the Act[2]to clarify and enhance the ESC's audit and compliance powers in respect of VEET came into effect. These enhanced powers included a power under section 19A of the Act for the ESC to require APs to obtain independent audits of their installations before VEECs may be created.

As a result, the ESC will require APs to undertake compliance inspections of each ceiling insulation installation by a qualified, and ESC approved, inspector before VEECs may be created for the installation. The scale of these inspections may be reviewed over time by the ESC based on the performance of individual APs with the view of determining whether the level of inspections may be reduced.

The ESC, in consultation with Energy Safe Victoria, will establish a panel of licensed electrical inspectors who may be engaged by APs to conduct post-installation inspections of ceiling insulation installations, to confirm amongst other things, whether the installation is electrically safe. A copy of the inspector's inspection report will be provided to the AP and to the ESC and VEEC creation requests will be required to include evidence that each installation was inspected and that it passed its inspection.

Where APs refuse to undertake such inspections, the ESC will direct APs to undertake inspections under section 19A and in the event the AP does not comply with that direction, the ESC may suspend or revoke the AP's accreditation3.

3.4 ESC Auditing and Compliance

In addition to checks to ensure the appropriate documentation is submitted by APs with their requests to create and register VEECs, the ESC may conduct compliance audits or investigations of APs as part of its audit and compliance program to verify whether activities have been undertaken in accordance with the requirements of the scheme and whether VEECs have been properly created.

Where such audits or investigations reveal that installations have not been properly undertaken or where there are deficiencies in the creation of VEECs, the ESC has a range of compliance sanctions that it may utilise to address instances of non-compliance.

The ESC may:

  • impose enforceable undertakings on APs to surrender valid VEECs to make good for improperly created VEECs;
  • impose restrictions or conditions on an AP's accreditation under s.14B;
  • refuse to register VEECs if audits find significant non-compliance;
  • suspend or revoke an APs accreditation;
  • prosecute an AP for breaches under the Act and seek orders for pecuniary penalties.

3.5 Breaches of Electricity Safety

Although the Electricity Safety Act 1998 prohibits the installation of unsafe electrical equipment and prohibits the carrying out of electrical works by unqualified persons, it does not directly prohibit other works that impact on the safety of electrical equipment.

As a result, a legislative amendment was made in 2011 to create an explicit prohibition under the Electricity Safety Act 1998 on carrying out building works that a person knows or should reasonably be expected to know will make the premises electrically unsafe4.

The effect of this amendment is to enable Energy Safe Victoria (ESV) to prosecute ceiling insulation installers under the Electricity Safety Act 1998 for contravening this prohibition.

Accordingly, in addition to compliance and enforcement activities the ESC may undertake in relation to contraventions of the requirements of the Act, the ESC has established cooperative information sharing arrangements with ESV to notify ESV of each premises insulated under VEET.

This information sharing arrangement enables ESV to be able to identify whether any electrical safety incidents involving ceiling insulation are connected to installations that occur under VEET. In the event, ESV will inform the ESC who, as the administrator of VEET, could investigate whether there had been any breaches that could be pursued under VEET.

Similarly, where the ESC discovers a possible breach of electrical safety as part of its administration of the ceiling insulation activity under VEET, the ESC will refer the alleged electricity safety breach to ESV for further investigation under ESV's powers.

4 Additional measures

To assist ensuring that appropriate safeguards are in place to protect consumers from potential safety risks associated with ceiling insulation and to protect the integrity of the VEET scheme, the former DPI engaged Futura Consulting (Futura) to undertake an independent review of the suitability of the measures (outlined in section 3 above) in light of lessons learnt from the HIP.

To this end, Futura was engaged to undertake a "due diligence" review of the various authoritative assessments conducted into the HIP to identify whether there are any gaps in the measures introduced by the former DPI and ESC to address the risks associated with ceiling insulation under VEET. Futura's Ceiling Insulation Due Diligence Review (attached as Appendix B) generally supported the re-introduction of ceiling insulation under VEET but made recommendations on four program elements that required attention. Futura also made some additional recommendations in respect of non-risk related activities that would assist in improving the administration of ceiling insulation under VEET.

A summary of Futura's key recommendations and the Deparment's response to those recommendations are set out in the following table:

Futura Recommendation

Former DPI response

1. Eligible products

There is some potential for suppliers and consumers to be confused about whether foil insulation materials are allowed under VEET – clarification should be provided to give service providers and consumers guidance in this area.

Support

Given that the scope of the ceiling insulation standard AS 3999-1992 explicitly states that it is not intended to apply to reflective foil laminate thermal insulation materials, the Department considers that VEECs may not be created for the installation of foil insulation products.

It is not anticipated that the exclusion of foil will have any significant effect on the scope of ceiling insulation products that may be installed under VEET as the installation of foil insulation in Victoria is rare.

In addition the Department understands that Standards Australia is undertaking a review of the foil insulation installation standard AS/NZS 4200 scheduled to be completed in 2013. The Department will not consider the possibility of including foil insulation under VEET until that review is complete.

It is proposed that ESC include clarification on this matter in an Explanatory Note.

2. Installer Training

The ESC's Explanatory Note specifying mandatory training for ceiling insulation should be revised to:

a) clarify apparent inconsistencies between the alternative OHS training courses specified; and

b) specify requirements relating to work experience, and supervision requirements for inexperienced installers.

Support in Principle, subject to further investigation

It is proposed that the ESC:

a) review the specified training units; and

b) investigate specifying that an installation installer must have proof of completed training and have accumulated at least six months' experience working under the supervision of an insulation installer 'supervisor' who has a combination of 2 years installation experience, proof of completed training, and a reference from an insulation manufacturer or distributor of insulation product.

3. Pre-installation inspection

The ESC should establish either:

a) guidance on the type of information to be documented as part of the assessment to ensure that all risks are assessed; or

b) a check procedure to ensure that a pre-installation risk assessment has been carried out.

Option (a)Supported

It is proposed that the ESC provide general guidance to APs on undertaking pre-installation risk assessment by reference to Australian Standard AS 3999. APs will be asked to demonstrate how they will satisfy their risk mitigation obligations.

This will enable the ESC to identify competent APs in assessing requests for approval to undertake ceiling insulation activities under VEET.

Option (b) Not Supported

The Department considers it would not be appropriate for ESC, as the VEET scheme administrator, to prescribe an approach to pre-installation risk assessments. Doing so would be in conflict with the aims of outcomes based risk mitigation and inconsistent with the ESC's role as an administrative authority, rather than as a safety regulator. Accordingly, installers should retain responsibility for undertaking their own assessments consistent with recommended industry practices.

4. Post-installation inspection

4. Post-installation inspections conducted by ESC approved inspectors should include inspections relating to the thermal performance of the installation and not be confined to electrical safety.

Support in Principle

The ESC will investigate the extent to which the inspections by ESC approved electrical inspectors can include matters relating to the thermal quality of installations which may be outside the normal competency of an electrical inspector. It is anticipated that inspections will at a minimum include confirmation that there are no inappropriate gaps in the insulation and that the work had been carried out in a workman-like manner.

In addition, to the key recommendations above, Futura made the following additional recommendations around non-risk related program refinements:

Futura Recommendation

The former DPI response

5. Track industry capacity to meet demand

The DPI could conduct quarterly or half yearly reviews of the ceiling insulation programs performance. These reviews could involve tracking and monitoring of ceiling insulation take-up against forecasts, and regular consultation with the insulation manufacturing and installation industry. This activity would assist the DPI in early identification of any potential product supply, quality and safety issues.

Support in Principle

The ESC reports annually on the performance of the scheme to the Minister[5]. The Department and the ESC will monitor the uptake of ceiling insulation under VEET and assess whether it is necessary to undertake more frequent formal reporting.

6. Implement a public awareness raising and communication strategy on ceiling insulation.

Concerns over the Commonwealth HIP scheme may still be top of mind for many Victorian consumers. It will be important for the DPI to differentiate the VEET ceiling insulation initiative from the HIP and to help restore consumer confidence in ceiling insulation. The DPI could implement a public awareness and communication campaign to achieve this aim. The campaign could also incorporate an education component that provides consumers with advice about appropriate insulation for their particular circumstances.

Noted for further review

The former DPI acknowledged that Victorian consumers may still have residual concerns about Government support for ceiling insulation given the outcomes of the Commonwealth's HIP. Any public awareness campaign aimed at restoring consumer confidence in this activity will need to be carefully considered.

The Department will undertake a further internal review of the need for a public awareness campaign.

7. Publish list of ineligible products to increase consumer information.

The ESC maintains a register of VEET approved ceiling insulation products that are eligible to create VEECs. The ESC could also produce a list of products that have been submitted for approval but have been deemed to be ineligible under the VEET. Consumer access to an ineligible products list would add another layer of consumer protection to the scheme and help raise consumer awareness of the types of products to avoid.

Not Supported

The ESC has no role in respect of ceiling insulation outside of the VEET scheme. Insulation products that are not eligible to be installed under VEET may still be valuable as insulation products independently of the scheme. To list otherwise valuable insulation products that would not be eligible to be installed under VEET may be misleading, rather than serve to provide additional consumer information.

8. Survey installers to assess if the new training regime is on target.

Insulation installers are required to invest time and resources in completing the minimum level of mandated coursework in order to meet the minimum accreditation requirements to become an insulation product AP. The ESC could consider undertaking routine surveys of installers, insulation manufacturers and associations to obtain feedback on the quality and relevance of the coursework being required. The feedback from these sources could be used to refine and update the mandated coursework training.

Support in Principle

As part of its monitoring and administration of the VEET scheme, the ESC undertakes periodic reviews of various matters relating to the operation of the scheme. The ESC will consider including, as part of these periodic reviews, reviews of training requirements specified in relation to ceiling insulation activities.

5 Other Issues

During stakeholder consultations undertaken in 2011 in the lead up to the Minister's decision to extend the suspension of ceiling insulation from VEET, written submissions were received from the following four stakeholders:

  • CSR Limited (Bradford);
  • Enviroflex;
  • Insulation Council of Australia and New Zealand (ICANZ); and
  • Wren Industries Pty Ltd.

In addition to the issues addressed in earlier sections, two additional issues were also raised. These issues are discussed below.

Incentive level available under VEET - Requirement for householder co-payments

Stakeholders provided differing views on the level of incentive that VEET should provide to households for the installation of ceiling insulation under the scheme. One stakeholder submitted that if ceiling insulation is to be reintroduced to VEET, a discount factor should be set to require that households make a co-payment for having ceiling insulation installed. Doing so would encourage householders to be more invested into ensuring that insulation was properly installed and mitigate the risk of poor installations and rorting.

Another stakeholder submitted the alternative view that if ceiling insulation is to be reintroduced, the full level of emissions abatement attributed to installing ceiling insulation should be restored.

The monetary value of the incentives available to householders for whom an AP undertakes an activity is dependent on a combination of the number of certificates that the AP may create for doing the activity, and the trading price of those certificates.

VEET is a market based trading scheme designed to deliver the emissions reductions at the lowest cost to consumers. To adjust the level of emissions savings on the basis of the overall monetary value of the discounts available to householders introduces interventions that may distort the operation of the market. In addition, fluctuations in the price of certificates will inherently influence any monetary contribution that a householder might be required to make.

The former DPI considers that the number of certificates that may be created in respect of an activity should be determined on the same basis as other activities. Any proposal to single out an individual product for a partial discount factor should only occur in exceptional circumstances and in a manner that is consistent with the Act (in particular  the requirements of section 18).

In the case of ceiling insulation, the past experience of the poor implementation of a different subsidy scheme, could be such an exceptional circumstance. Furthermore, it may be appropriate for gradual phase-out of the current discount factor rather than allowing the existing discount factor to expire in full.

The Department invites comment on this aspect.

Uncertainties regarding emissions reductions achieved from ceiling insulation

One stakeholder made submissions supporting the continued suspension of ceiling insulation from VEET in light of the criticisms raised in the 2010 Senate Inquiry6.The criticisms in the Senate Inquiry concerned the lack of independent research and testing to investigate claims about the performance of ceiling insulation and to inform ceiling insulation policy generally in Australia. Claims were also made that Standards Australia's decisions, including in relation to the insulation materials standard AS/NZS 4859.1, can be unduly influenced by sectional interests and that Standards Australia's governance and funding arrangements should be reviewed.

The Department considers that these matters concern the establishment of building and technical standards more generally and are beyond the scope of matters capable of being addressed by VEET in isolation.

The level of deemed emissions reductions achieved through VEET has been determined based on technical advice provided by Sustainability Victoria with reliance on the evidence and data available and is consistent with the level of emissions reductions recognised under South Australia's Residential Energy Efficiency Scheme. Ceiling insulation under VEET aims to assist householders who have no ceiling insulation at all, to have ceiling insulation installed that will help householders manage their energy costs. Accordingly, it is the former DPI's view that the availability of incentives under VEET be based on the current body of available evidence and standards. As for all products under VEET, where evidence emerges that indicate the level of emissions reductions recognised under VEET should be reduced, the abatement levels can be adjusted either through the declaration of a (non-zero) discount factor, or by an amendment to the abatement factors provided in the Regulations.

6 Consultation questions

In light of the matters addressed in this issues paper and the outcomes of Futura's Due Diligence report, in addition to commenting on any of the matters in this document, stakeholders may wish to specifically consider the following consultation questions:

Q: Are the measures taken under VEET in respect of the reintroduction of ceiling insulation under the scheme suitable?

Q: Are the proposed responses to the Futura report recommendations sufficient to allow the reintroduction of ceiling insulation under VEET?

Q: With reference to Futura recommendation 5, does industry have the capacity to meet the demand for ceiling insulation supplied under VEET?

Q: Are the specified mandatory training units appropriate?

Q: Should there be a gradual phase out of the current discount factor rather than allowing the current discount factor to expire in full?

Q: Are any additional measures necessary?

Appendix A – ESC Ceiling Insulation Compliance Process Flow Chart (Draft)

Click on the image to view a larger version of Appendix A ESC Ceiling Insulation Compliance Process Flow Chart (Draft)
Click on the image to view a larger version of Appendix A – ESC Ceiling Insulation Compliance Process Flow Chart (Draft)

1 Amendments made by S.R. No. 32/2012 Victorian Energy Efficiency Target Amendment (Further Prescribed Activities) Regulations 2012, which came into effect on 17 May 2012.2see Part 3 of the

Energy Legislation Amendment (Bushfire Mitigation and Other Matters) Act 2011.

3see section 14A(1)(c) of the Victorian Energy Efficiency Target Act 2007.

4 see section 43A of the Electricity Safety Act 1998, inserted by the Energy Legislation Amendment (Bushfire Mitigation and Other Matters) Act 2011.

5required under section 7(3) of the Act.

6 see The Senate - Environment, Communications and the Arts References Committee – Energy Efficiency Homes Package (ceiling insulation), July 2010, recommendations 6 – 11.

Appendix B – Futura Consulting, Ceiling Insulation Due Diligence Review

View Appendix B - Futura Consulting, Ceiling Insulation Due Diligence Review

Page last updated: 24/06/20