Energy Bill [Lords]

Memorandum submitted by Isothane Ltd (EN 27)

Summary

1. Given the concentrations of hard to treat cavity properties in some of the most deprived areas appropriate and relevant recognition of energy efficient closed cell PUR injected in-situ insulation measures within the Green Deal would, we consider, improve the housing conditions of a great many of our most vulnerable residents and help address the combined agendas of health inequalities, fuel poverty and carbon saving, and reduce the risk to homes from flooding.

2. The practical steps to reduce the impact of flooding starts with being better informed and using the information available and is not currently being applied throughout the whole of the construction industry. The advice given in the Pitt Review and report published jointly by DEFRA, DCLG and the Environment Agency should be included in the Green Deal and the forthcoming revisions and amendments to Part L of the Building Regulations if we are to avoid major remedial works and high costs associated with drying out, removal and replacement of incorrectly specified insulation measures in flooded homes.

3. By taking this approach Central Government can jointly tackle several key issues in a cost-effective manner.

4. We agree that, "Consumer protection (must) be built into the Green Deal from the word go" (DECC Press Release dated 9th December 2010 refers) and includes hard to treat homes including homes with hard to treat cavities.

5. A recent study, A review of the delivery tools used to improve hard-to-treat homes project by ACE, estimates that there are 10 million or 40% of UK homes are hard to treat and include "hard to treat cavities". More recently, industry bodies have iden tified that there are around 8m- 9m non traditional cavity walls capable of being filled including circa 4m partial fill, and steel/timber framed system built and circa 4m hard to treat including narrow cavities, coursed stone and random stone. In addition, 5.2m homes in England alone are at risk of flooding. Figures for flood risk for Scotland, Wales and N Ireland are unknown.

6. The outcome of a survey of circa 170 social landlords carried out in late 2010 in the North of England indicates that many of the properties which are currently labelled "hard to treat solid walls" have been incorrectly classified and are actually hard to treat cavities. These cavities are narrow or are irregular and cannot be insulated with standard measures but can be treated with closed cell PUR injected in-situ insulation.

7. Closed cell PUR injected in-situ insulation has been proven in use for over 25 years to be the most economical, efficient and practical solution for many of the properties designated as being Hard-To-Treat-Homes including:

 

Ø Coursed Stone and Random Stone properties having non-standard cavities

Ø Narrow, sub 50mm cavities and irregular width cavities incorrectly classified as solid walled, 

Ø Non-Traditional House Systems,

Ø High Rise Blocks,

Ø Properties with structural defects, corroded or missing cavity wall ties, weak defective mortar joints, defective damp proof courses,

Ø Properties unsuitable for traditional cavity insulation measures due to exposure to high wind driven rain conditions

Ø Properties unsuitable for external wall insulation due to planning restrictions and structural problems

Ø Properties unsuitable for internal wall insulation due to unacceptable disruption of tenants and costs of relocation

Ø Properties at risk of flooding.

Traditional Housing

8. For example, various Local Authorities including Blackburn with Darwen have thousands of Hard-To-Treat-Homes that without closed cell PUR injected in-situ insulation would not be able to be tackled economically. The use of closed cell PUR injected in-situ all in one system solution has helped Blackburn with Darwen to develop sustainable refurbishment solutions for poorly performing, difficult to treat privately owned properties. It has done this by providing fabric insulation, draught proofing and increased life span of the fabric of the building, together with improved thermal performance to substantially reduce energy demand and wastage through the building fabric. This has resulted not only in consequent significant financial cost benefits to the residents but, in addition, the solution also provides high resistance to wind driven rain penetration overcoming damp problems associated with these properties, thereby improving the health and wellbeing of the residents of Blackburn with Darwen.

High-Rise Blocks

9. Liverpool, Edinburgh, Watford and Walthamstow High-Rise Structural Stabilisation Solutions. 

Ø For the Liverpool project, 16 tower blocks were similarly refurbished which saved the public purse approximately £8 million at the time. 

10. Given the concentrations of such hard to treat cavity properties above in some of the most deprived areas appropriate and relevant recognition of closed cell PUR injected in-situ measures within the Green Deal would, we consider, improve the housing conditions of a great many of our most vulnerable residents and help address the combined agendas of health inequalities, fuel poverty and carbon saving, and reduce the risk to homes from flooding.

Flood Risk

11. 5.2m homes in England alone are at risk of flooding. For many people, flooding is a fact of life.

Ø In a report published jointly by DEFRA, DCLG and the Environment Agency (Improving the flood performance of new buildings) rigid closed cell PUR foam is shown to be the best performing when installed into cavity walls. The report states "Cavity insulation should preferably incorporate rigid closed cell materials as these retain integrity and have low moisture take-up. Other common types, such as mineral fibre batts, are not generally recommended as they can remain wet several months after exposure to flood water which slows down the wall drying process. Blown-in insulation can slump due to excessive moisture uptake, and some types can retain high levels of moisture for long periods of time (under natural drying conditions)."

Ø The Association of British Insurance (ABI) in 2001 stated that only closed cell insulation should be used in flood risk areas. This product will provide an opportunity to insulate properties in flood risk areas as well as acting as mitigating risk and cost to the public and private sector purse as local authorities under their carbon and environmental plans take a co-ordinated approach with partner organisations such as the Environment Agency.

Ø The Pitt Review which was called for following the 2007 floods states that "Resilience measures are worthwhile if incorporated into the design of a new property or when installed in a building which is being extensively refurbished. In these situations the extra cost is relatively low compared to standard materials, with resilience measures becoming cost beneficial for properties with a four per cent or greater annual chance of flooding."

Learning lessons from the 2007 floods. Sir Michael Pitt (June 2008)

Ø "On Thursday 19 November 2009 severe flooding hit Cumbria. Over 1,500 properties were flooded and 200 people were evacuated. David Oakes – Environment Agency said, "one year on we’ve helped reduce damage to (only) 45 properties".

12. The devastation caused by the floods in 2007 and 2009 are still fresh in the memory. All home owners need to be advised of the additional risks and remedial costs (£3,000 - £4,000) associated with removal and replacement of incorrectly specified and installed standard insulation measures and to be informed of the correct combined flood resilience and insulation measures they can take to protect their properties using closed cell PUR injected in-situ insulation.

13. The practical steps to reduce the impact of flooding starts with being better informed and using the information available and is not currently being applied throughout the whole of the construction industry. DECC Press Release dated 9th December 2010 requires that there should be, "A competitive market for Green Deal delivery which enables new market entrants, like high street retailers, builders’ merchants or Local Authorities, to be advisers, providers and accredited installers", It is therefore imperative that information relating to flood risk should be made widely available and be included in the Green Deal and the forthcoming revisions and amendments to Part L of the Building Regulations if we are to avoid major remedial works and high costs associated with drying out, removal and replacement of incorrectly specified insulation measures in flooded homes.

14. When carrying out an energy survey it is essential that the Accredited Advisor takes into account the projected rainfall together with the advice given in the above Pitt Review and report published jointly by DEFRA, DCLG and the Environment Agency and produces a flood risk assessment for the property to be treated.

15. The Accredited Adviser must also advise the homeowner of all essential maintenance cost associated with the proposed insulation measures. Failure to specify the correct insulation measure for the property or to carry out essential maintenance requirements in connection with the measure may result in severe damage to the original structure and/or premature failure, delamination and detachment of the measure, and may also invalidate any system guarantee.

16. By taking this approach Central Government can jointly tackle several key issues in a cost-effective manner. A step change is needed if we are to achieve the level of CO2 savings required to meet national targets. We need to ensure that the best technical solutions and most cost effective measures are identified for each property taking into account the condition of the structure and any defective, corroded or missing wall ties, the wind driven rain exposure conditions and flood risk, and that the measures are correctly installed by appropriately qualified and experienced installers.

June 2011

Prepared 16th June 2011