Submission from Knauf Insulation

Ceiling Insulation Regulation Amendments Consultation 2016
Energy Policy and Programs
Department of Economic Development, Jobs, Transport and Resources
GPO Box 4509
Melbourne VIC 3001

Knauf Insulation welcomes the opportunity to participate in the formulation of policy in regards to the proposed reintroduction of Ceiling Insulation into the Victorian Energy Efficiency Target.

It is widely acknowledged that ceiling insulation is the most cost effective way for a home to improve its energy efficiency; this is also supported by the Clean Energy Council, Sustainability Victoria, and the Energy Efficiency Council.

With regards to updating the referenced ceiling insulation standard in the Victorian Energy Efficiency Target regulations to AS3999-2015, Knauf Insulation would strongly support this change.

With regards to restricting the type of Insulation eligible for VEET incentives to non-conductive products, Knauf Insulation supports this position and would again reiterate the following findings regarding Reflective Foil Laminates (RFL) when installed into a domestic ceiling space.

Report of the Royal Commission into the Home Insulation Program.

Section 9:
ADVICE, WARNINGS AND RECOMMENDATIONS: SAFETY AND THE USE OF REFLECTIVE FOIL LAMINATE INSULATION
Findings (Page 209)
9.5.1 "The Installation of RFL sheeting ought never to have been permitted under the HIP."

Ceiling Insulation Due Diligence Review 2012  Futura Consulting

Excerpt from Section 5.3.1 Eligible Activities:
"The DPI and the ESC should consider providing greater clarity over the current status of foil insulation in the VEET by issuing an Explanatory Note stating its position on foil insulation. Given the safety issues noted earlier and concerns over the performance characteristics of foil insulation in Victoria it is recommended that installing foil insulation be explicitly excluded from the VEET scheme, at least for the time being." Page 22.

Review of Ceiling Insulation and the Victorian Energy Efficiency Target
KPMG Sept 2015
Recommendation 2.
"Deem Insulation products that contain foil to be ineligible for approval under the VEET through an explicit statement in the VEET scheme documents."

If you would like to discuss any of the above feel free to be in contact.

Regards

Neil Stephens
Business Development  Vic/Tas
KNAUFINSULATION

Australia
Head Office
Unit 1, 44 Borthwick Avenue
Murarrie QLD 4170
Phone +61 7 3393 7300
Mobile: +61 (0) 447 735 835
www.knaufinsulation.com.au

Page last updated: 24/06/20