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Memorandum submitted by Rockwool Ltd GJS02
1. Introduction to Rockwool
1.1. Rockwool welcomes the opportunity to respond to the Environmental Audit Committee inquiry into 'green jobs', to look into how the UK can maximise the environmentally positive opportunities arising from changes in public spending intended to help tackle the recession. Our response centres on the construction and construction products industry of which we are a part.
1.2. Rockwool Ltd is the UK's leading manufacturer of stonewool insulation for thermal, fire and acoustic protection. The parent company, Rockwool International A/S, has its headquarters near Copenhagen in Denmark and 35 operating companies throughout Europe and North America.
1.3. Rockwool insulation products are made primarily from volcanic rock and are used in a diverse range of industrial, commercial and residential settings.
1.4. Rockwool makes every effort to ensure that they manufacture their products in a way that is sustainable and environmentally friendly. For example:
1.4.1. The Rockwool production process uses large quantities of by-products from the steel-making industry that would otherwise be landfill. Currently, between 20% and 30% of the total furnace charge is made up of steel slag.
1.4.2. Off-cuts from cutting and shaping Rockwool products during production are recycled directly back into the manufacturing process. Currently, this accounts for approximately 10% by weight of the finished product.
1.4.3. Rockwool Ltd & industry partners are increasingly involved in WRAP approved schemes to recycle waste Rockwool material that may be generated during installation, conversion or end-of-life disposal.
2. Energy efficiency
2.1. Rockwool believes that energy efficiency is essential as part of a green economy in order to reduce the use of fossil fuels and to reduce carbon emissions. Buildings hold the largest potential for energy savings as most of the energy in buildings is used for heating and cooling. Effective use of insulation has huge potential to improve the energy efficiency of the UK building stock. 3. New buildings
3.1. It is currently possible to build new houses that consume 70% less energy for heating than Europe's strictest building regulations require. It is important that the Government continues to support and challenge architects, designers and construction professionals to ensure energy efficient design of new buildings.
3.2. Encouraging energy efficiency can be partly achieved through existing and upcoming initiatives including the planned revision of Part L of the Building Regulations, the Heat and Energy Saving Strategy and the Zero Carbon Homes policy. It should be carefully considered what jobs and skills are required to implement these - for example what training is required for building control bodies to ensure that building regulations are enforced. The Government could also work with professional accreditation bodies to ensure increased emphasis on energy efficiency in the education of professionals. Arguably, one of the least effective aspects of Building Regulations relates to compliance, feedback and the consequences of non-compliance. Changes are therefore needed to Building Regulations to introduce clear processes for monitoring and reporting; supported by sufficient independent inspection resources. The consequences of non-compliance and their associated enforcement also need to be formulated. These procedures are needed equally for new-build activities and those undertaken to upgrade the energy efficiency of existing buildings. It is particularly important for upgrading schemes that the delivery of energy savings against agreed milestones must be monitored, recorded, reported and acted upon to target measures effectively. Clear processes for monitoring, reporting and remedial/corrective action are therefore needed.
4. Retrofitting existing building stock
4.1. The scale of the task of retrofitting the existing building stock to achieve its energy efficient potential is vast, as indicated by a recent joint report from the Economic and Social Research Council and Technology Strategy Board. The report estimates that 'virtually all the 24 million existing buildings in the UK would need some attention to reduce their emissions by 40 per cent. To complete the task in 40 years we would need to refurbish an entire city the size of Cambridge every month. If we assume that each intervention set would take a team of trained workers two weeks, we would need 23,000 teams of people to work at this rate non-stop for the next 500 months.'[1]
4.2. These figures show that a large number of green jobs would be created if the Government committed to realising the potential energy efficiency savings of all existing buildings through retrofitting of insulation and other measures.
4.3. In order that insulation performs as it is designed to do and provides the maximum possible thermal properties, it is important that those fitting insulation are properly trained. Rockwool is chairing a trade association (Eurisol) initiative to assess the need for improved industry guidance for the use and installation of insulation. This is an area in which green jobs can be created and environmental benefits of insulation improved through better training.
4.4. It is also imperative that the fitting and maintenance of insulation is monitored, which involves education of the building industry and the public and further training of individuals working within the Local Authority Building Control system.
4.5. Rockwool supports the Government's recent initiatives to improve the energy efficiency of the UK's existing housing stock; such as raising the targets for CERT and the creation of a new Community Energy Saving Programme (CESP). However we are strongly opposed to the proposed scoring/incentive systems for these schemes, which we believe to be overly complicated and open to 'gaming'. The nature of the proposed scoring significantly reduces the potential for these schemes to deliver the intended levels of energy/carbon savings and, as a consequence, may adversely affect the businesses that supply key energy efficiency products. Rockwool urges Government to ensure that the operation of schemes such as CERT, CESP and HESS are simple and understandable in order to reduce the opportunity for 'gaming' and to focus targets and funding on specific measures; such as the upgrading of hard-to-treat buildings. Separate, ring-fenced funding should be provided for 'hard' and 'soft' measures to ensure that unproven, 'soft' behavioural measures are not undertaken at the expense of robust 'hard' measures, resulting in a relative reduction in savings from the schemes (eg building fabric improvements should receive separate funding from energy advice). Rockwool advocates the earliest possible move within all schemes to genuine 'whole-house' measures for existing buildings. It is extremely important that energy-saving measures that are financially and practically viable when undertaken as part of a combined project (but may not be viable as separate, disruptive activities) are captured. For example, hard-to-treat measures such as solid wall insulation should be installed at the first (eg) 'CERT' visit when the loft is insulated/topped-up or other energy-saving measures are installed, not second or third time around. Synergies with other energy-saving measures such as the installation of low carbon heating technologies are also applicable.
4.6. During previous EEC/CERT transitions, there has been considerable uncertainty which has lead to reduced EEC/CERT activity, workers being laid off and the UK's skills base & manufacturing capacity being reduced. Such a situation between CERT and post-2012 schemes must be avoided by the implementation of early, clear commitments to post 2012 schemes and the implementation of smooth transitional arrangements between these schemes. Government needs to provide a binding commitment to undertake an ambitious energy-efficiency programme of works with clear milestones at least up to 2020 and perhaps up to 2050; driven by several £billions per year of funding. For example, 'whole-house' packages of improvements for 1.8 million households a year - represents spending of £18 to 72 billion per annum (assuming between £10 000 and 40 000 per upgrade). Development of innovative funding schemes is therefore needed - for example energy suppliers could be encouraged to provide funding for energy improvements in the form of 'energy mortgages' linked to the properties upgraded, not the building owners.
5. Construction waste
5.1. The Department for Environment, Food and Rural Affairs (DEFRA) recognises that the construction, demolition & excavation (CD&E) sector generates more waste in England than any other sector, and is the largest generator of hazardous waste - with around 1.7 million tonnes of hazardous waste generated each year.[2]
5.2. Rockwool Ltd has made a conscious choice to invest significantly in recycling facilities in order to reduce the burden on landfill sites and to help minimise the depletion of resources. Three quarters of the Group's stonewool waste is currently recycled, and Rockwool Ltd & industry partners are increasingly involved in WRAP approved schemes to recycle waste Rockwool product material that may be generated during installation, conversion or end-of-life disposal.
5.3. There is great potential for green jobs to be created by developing skills and expertise on the recycling or appropriate disposal of construction and demolition waste.
5.4. The European Waste Catalogue lists a number of products frequently found in construction waste that should be considered to be hazardous waste and disposed of as such. Hazardous waste from construction and building demolition includes waste such as foam propellants (as used in pre-2004 foam insulation), solvents, tar, and asbestos. [3]
5.5. The use of ozone-depleting substances in building insulation foams has been banned in the EU since the beginning of 2004. However, the significance of plastic foam insulation entering the waste stream is expected to increase significantly in the medium to longer term as more buildings containing these panels are redeveloped. The Government has made a rough approximation that one million tonnes of buildings foam exists in buildings in the UK, and suggests that around 100,000 tonnes of ozone-depleting substances might be contained within these.[4] Furthermore, this bank of HCFCs contain global warming potential which equates to 240 million tonnes of carbon dioxide. This is equal to almost two-thirds of all the carbon dioxide emissions from the whole of the UK in 2007.
5.6. It is clear that the potential environmental impact of building insulation foams entering the waste stream is substantial, if they are not disposed of properly. Developing skills and expertise in the demolition and waste disposal industry to dispose of building foams and other hazardous waste appropriately should be seen as an opportunity for the creation of green jobs. There is also the opportunity to establish a skills and knowledge base which can be exported to other countries who face this foam-legacy issue.
6. Tax Incentives 6.1. Rockwool would encourage the Government to consider tax incentives, which include the following; 6.1.1. Lower council tax bands for buildings that achieve specified levels of improvement against the existing Energy Performance Certificate (EPC) rating. 6.1.2. Lower council tax bands for buildings achieve one of the top EPC ratings. 6.1.3. Rates of Stamp Duty, which vary depending upon the EPC rating. 6.1.4. Income tax relief on qualifying energy improvement works (again such incentives could be linked to improvements in existing EPC ratings). 7. Government to act in an exemplar role 7.1. It is Rockwool's view that the Government must do much more to lead by example. Public buildings owned and rented by the government account for a very significant proportion of the UK's total buildings. A determined and visible programme to ensure that all public sector buildings (rented and owned) are quickly brought up to the highest energy efficiency standards is required.
May 2009 [1] Economic and Social Research Council/ Technology Strategy Board Seminar Series Mapping the Public Policy Landscape 'How people use and misuse buildings' (April 2009) [2] Defra Recycling and Waste: Construction Waste (Feb 2009) Figures from Waste Strategy for England (2007) http://www.defra.gov.uk/environment/waste/topics/construction/index.htm http://www.defra.gov.uk/ENVIRONMENT/waste/strategy/strategy07/pdf/waste07-strategy.pdf [3] European Waste Catalgoue, http://www.environment-agency.gov.uk/static/documents/EWC_31-03-09_CH.pdf [4] Hansard 25 Jun 2008 : Column 304W |