To: Tim Renouf, Secretary AFIA – Aluminium
Foil Insulation Association Inc. (Vic 1998)
From: Robert Enker, Victoria Building Commission
Re: Testing of Building Insulation Materials
Date: 10/12/2001
____________________________________________________________________________________
Dear Mr. Renouf,
You have recently provided a variety of background material on behalf of AFIA to Peter Nassau,
BCC Director Building Quality. The substance of this advice relates to the case for improving
the scientific basis for determining the R-values of thermal insulation materials such as reflective
foil.
The Commission recognises the importance of scientifically valid, verifiable information on
building insulation R-values to building consumers. Such information is also important to
building regulators involved in setting and enforcing building energy efficiency standards, whether
these are based on elemental deemed to satisfy provisions, or on holistic
building energy rating techniques.
We recognise that shortcomings exist in relation to analytical process in the NatHERS energy rating
tool that is widely accepted in southern Australia. Potential deficiencies in default R-value settings
in NatHERS for various insulation materials are also recognised. It is our understanding that these
shortcomings are most pronounced in relation to well ventilated houses designed and built to suit the
warmer tropical regions of Australia than houses designed
for temperate regions of the country.
It is the view of the Commission that the review and upgrading of NatHERS is an issue for national
energy policy
processes.
The appropriate vehicle for undertaking such a review is the Australian and New Zealand Minerals
and Energy Council (ANZMEC) whose mission is, inter Australia, “to consult on the nation’s
energy needs, resources and policies”. As you are probably aware, the Energy Management Task Force
(EMTF), reporting to ANZMEC, is custodian of the NatHERS model at the national level. Victoria is
represented on the EMTF by the Sustainable
Energy Authority (SEAV).
A comprehensive review of NatHERS would be expected to include in its terms of reference the
verification of R-values by means such as physical simulation techniques. We will be suggesting to
SEAV that such option be considered; and also playing an active role in supporting continuing
progressive development of NatHERS.
For these reasons, it is suggested that further correspondence from AFIA on these matters
would in future be more
appropriately directed to SEAV rather than to the BCC.
Yours truly,
Robert Enker
Senior Policy Adviser, Sustainability