Memorandum submitted by the National Insulation
Association
1. This submission is from the insulation
industry and has been produced by the National Insulation Association
(NIA) and the Cavity Insulation Guarantee Agency (CIGA). The NIA
represents the manufacturers and installers of insulation products
including cavity wall insulation, loft insulation and other innovative
products. CIGA provide independent Guarantees and Technical leadership
for Cavity Wall Insulation.
2. Due to the changes in Building Regulations
in April 2005, nearly all new boiler installations are energy
efficient (condensing) which will result in higher efficiency
in the generation of space heating. Therefore the key task for
Government is to ensure that this efficiently generated heat is
not simply escaping into the atmosphere through a lack of adequate
insulation. It is vitally important therefore to insulate the
remaining cavity walls, lofts and solid walls.
3. As an industry we support any work carried
out to help eradicate fuel poverty and ensure those on low incomes
can afford to properly heat their home. However, the only way
to ensure all those on low incomes benefit from a thermally efficient
home is to insulate all of the housing stock and therefore "future
proof" this stock. This means that where a low income householder
moves property we can be ensured that they move into a thermally
efficient home. It makes far more practical sense to look at how
we can insulate all the stock in the most cost-effective manner
as opposed to hindering the efficient delivery of carbon reduction
schemes with a focus on benefit claimants or the like.
4. A key area where those on low incomes
are not been adequately assisted at present is where they live
in one of the over six million properties which does not have
a cavity. The propensity to be fuel poor in a property with a
cavity is less than 5% yet this doubles to 10% of all those who
live in solid wall properties. This build type needs to be a priority
moving forward.
5. Market transformation to ensure the capacity
is built to deliver solid wall insulation in sufficient numbers
to insulate such homes is also vital to the future of the insulation
industry which has grown to deliver energy/carbon savings via
the installation of cavity wall and loft insulation with the encouragement
of Government. Government have already stated they wish for all
the remaining potential for these measures to be fulfilled by
2016-20, it is therefore vital that the solid wall market is transformed
to provide a future for our industry. If this is not achieved
then the future of our industry is at substantial risk which would
be an extremely negative development for the UK Plc and cost effectively
meeting the carbon targets set by Government.
6. Further interventions in the Private
Rented Sector to incentivise or regulate landlords to have cost
effective measures installed are also required. At the moment
there is no incentive for either tenants or landlords and this
is resulting in this tenure not receiving an "equitable"
amount of measures.
7. Work on how the implementation of Energy
Performance Certificates (EPC's) can be best utilised to encourage
landlords and householders to have cost effective energy efficiency
measures installed is urgently required. Due to the time that
it will take for sufficient numbers of EPC's to be delivered Government
cannot rely heavily on these to make a major contribution to the
cost effective delivery of measures in the short term. However,
these could be instrumental in the medium term provided these
highlight a channel of action for properties do not have sufficient
levels of insulation a channel to turn the advice into action.
8. A major omission in the cost-effective
delivery to date has been the lack of a whole house approach where
all effective measures are installed at the same time. A useful
starting point would be that no renewable energy heating and electricity
generation are installed until all cost effective insulation measures
have been professionally installed with the lofts and walls being
insulated at the same time.
9. This response is limited to the requirements
of the insulation industry to ensure that ALL housing stock is
brought up to a suitable thermally efficient standard. The insulation
industry requires certainty that this will happen and any policy
developments brought to bear will not be at the detriment of technical
physical measures being installed. More behavioral "soft"
measures could also have a future benefit as could further development
of less cost effective measures such as renewables. However, developing
the correct mechanisms to encourage these should neither delay
nor jeapordise all homes receiving the insulation measures they
require.
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