Memorandum submitted by Rockwool Ltd
SUMMARY
— Rockwool Ltd is the UK's leading manufacturer
of stonewool insulation for thermal, fire and acoustic protection.
— Maximising energy efficiency in new and existing homes
must be a design and construction priority in order for the Government
to meet its long-term emissions reduction targets. — The
Government must ensure that the regulatory framework is in place
to encourage energy efficient design and construction, and that
government schemes and building regulations are appropriately
resourced and enforced.
— Investment in training for the fitting
and maintenance of energy efficiency measures such as insulation
could improve the efficacy of such measures and create green jobs.
— The construction and demolition industry
creates more waste than any other sector. Future challenges, such
as the disposal of the legacy of building foams that contain ozone-depleting
substances, have yet to be addressed.
— Green jobs can be created, and the environmental
impact reduced through investment in research, facilities and
training in the demolition and waste sector.
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%. 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."[2]
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.[3]
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.[4]
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.[5]
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:
6.1.3 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
2 Economic and Social Research Council/Technology Strategy
Board Seminar Series Mapping the Public Policy Landscape "How
people use and misuse buildings" (April 2009). Back
3
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 Back
4
European Waste Catalgoue, http://www.environment-agency.gov.uk/static/documents/EWC_31-03-09_CH.pdf Back
5
Hansard 25 Jun 2008 : Column 304W. Back
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