Rectify the disparity of safety procedures for the Installation of insulation and downlights.

Until the Law of Fluid Dynamics i.e. 'all heat moves from warm to cold' is addressed, which is affected by downlights in ceilings, VEET and Mandatory Disclosure cannot be instigated.

SEPARATION GAPS for fire safety around downlights, NO MATTER WHAT THE GAP IS, are like chimneys allowing heat from the home interior to move into the cooler roof space.

The BCA states:

5% gaps in the ceiling area compromises bulk insulation reducing its effectiveness by up to 50%.

Allows a certain number of downlights to a designated thickness of insulation in ceilings. When more downlights are installed, the insulation thickness has to be increased.

Simple example:

One hole in a bucket filled with water (water being just like heat from a room below) With more holes, the wall of the bucket is thickened,

BUT more water (heat) escapes .

Therefore, more heat is lost from the rooms inside the building because of the downlight gaps for fire prevention.

A typical insulation installation around a downlight. A typical

Insulation used was pump in loose fill cellulose. Look at the method to hold back the insulation to achieve a 50mm airgap. If fibre batt insulation was used there would be a larger, easier to form square hole with heat venting from the downlight, see below. Top picture. Notice you see the ceiling plaster where the downlight and transformer is installed; this will radiate heat into the roof space.

These examples are where fluid dynamics is demonstrated; the uninsulated portion where the plaster sheet is exposed, or the open area above the downlight in the bottom picture, forming a chimney effect allowing heat to pour into the roof space. In top picture, this ceiling has fifteen (15) downlights. Energy efficiency at its best; makes a mockery of the Standards - that’s why they are a fraud regarding this issue.

Could someone in Government explain why this is allowed for energy efficiency?

The Victorian Government CAN address this issue.

The insulation industry know that this winter downlight issue is the most understated and 'hidden' issue, that decreases energy efficiency before any other measure.

Such as increasing the thickness, the 'R' value of insulation which defies the Law of Diminishing Returns .

Once the insulation 'R' value, which usually equates to thickness, reaches a certain thickness which does the majority of the 'insulating', any increase in thickness can't justify the additional costs.

There is a justification to address the downlight issue, especially in single story commercial premises who operate almost 24/7 using downlights.

HOW

Remove halogen, and replace with LED downlights. Cover the LED downlight with a cover that can tolerate 1000˚C, which will then allow

insulation to cover the downlight COMPLETELY, thus practically as possible sealing the chimney effect.

Why bulk fibrous insulation fails in hot climates, which in the future may be prevalent for all of Australia, if the Victorian Government Schemes of VEET and Mandatory Disclosure are adopted in other States of Australia.

The key Insulation Standard, has a Steady State Thermal Test Method for bulk insulations which for hot climates, not testing for long periods OR accounting for high temperature solar radiation.

Current test method, 4 hours at a mean temperature of 23˚C, is like asking 'the powers above' for test conditions 4 hours a day.

In reality, insulation is subjected to longer periods of heat generated by radiation, even on a cloudy day, and stores this heat.

Once insulation air pockets are saturated with heat, they emit this into cooler areas of the building, especially during hot periods.

Airconditioning ductwork suffers the same fate, the overwhelmed heated bulk insulation around the ductwork is cooled by the cool air moving through the ducting, Thus making the cooling unit worker harder and for longer periods of time. costing the consumer more running costs and emitting more greenhouse gases.

The million dollar 2013 CSIRO 5 Star Evaluation Report stated that thicker insulation, R 3.5 increased cooling costs in Melbourne by 37%.

FURTHER EVIDENCE QUESTIONING THE EFFECTIVENESS OF BULK INSULATION, IN HOT CLIMATES

Two reports were produced in late 2013, and have come to light in early 2014.

The implications of the 2013 CSIRO 5 Star Evaluation Report are very serious for the insulation industry and cannot be avoided. Additionally this report has not had public discussion or scrutiny.

We can reasonably conclude that increasing levels of bulk insulation R-values (as per CSIRO report) is likely to be causing a summer problem of higher energy costs for cooling.

The 2014 South Australian University report recommends the use of foil under all residential roofing.

First time in history, since the introduction of aluminium foil insulation in Australia in 1953.

Another unpleasant fact is that there is the reporting of cooling ductwork insulation summer R-values, which are measured at a “mean” temperature of 23˚C, as per the Insulation Standard AS/NZS4859.1.

This grossly misleads the public, because the mean temperature of ductwork insulation will be subjected to vastly higher 50 -70C˚, typically found in Australian roof spaces.

This issue cannot be avoided and must be addressed to help people survive in summer. Foil encasement of cooling ductwork is needed, in my opinion. What we see as foil sometimes around ductwork, I am informed, is not acting thermally as a radiant heat barrier, because it is not a pure foil laminate. Real time controlled in a climate simulator physical thermal testing is needed.

The truth must come out. This news item justifies the need for radically new thermal testing methods of insulation materials and cooling ductwork systems. Current testing methods do not reveal the truth.

“Too Hot to Handle: Life in a four-degree world” Climate Code Red (5 March 2014) http://www.climatecodered.org/2014/03/too-hot-to-handle-life-in-four degree.html?utm_source=feedburner&utm_medium=email&utm_campaign=Feed%3A+ClimateCodeRed+%28climate+code+red%29

CSIRO 5 Star Evaluation – Dec 2013   (11 Feb 2014, Dept of Industry website uploaded)

www.industry.gov.au/5StarEvaluation     *this report was finally revealed after persistent requests to Government

The Evaluation of the 5-Star Energy Efficiency Standard for Residential Buildings

"The CSIRO was contracted to evaluate the effectiveness of the 5-star energy efficiency standard for houses introduced in 2006, compared to the previous 3.5 to 4 star standard. Their work has culminated in this report, 'The Evaluation of the 5-Star Energy Efficiency Standard for Residential Buildings.

It is the first evaluation of energy efficiency standards for houses in Australia based on comparison of actual energy use in a large sample of houses. This comprehensive report has added to our understanding of how well energy efficiency star ratings in residential buildings actually work, for homeowners and builders alike.

The study monitored the energy use of more than 400 houses (with around half the houses undergoing more detailed monitoring of heating and cooling) in Brisbane, Melbourne and Adelaide, from June 2012 to February 2013."

Report Correction by Graeme Doreian

CSIRO Report Page 23

"1.3.3 ACCURATE RE-RATING

Figure 1-2 gives an overview of the distribution of data from the cohort of 209 households that originally had electricity data loggers, and the 414 volunteers whose houses had temperature sensors, rating assessments and surveys."

Commentary by G. Doreian

Key findings: page 81 TABLE 9-2 *manually calculate % increases, from 4 Star to 5 Star level

Electricity cost increases for cooling in summer with increasing ceiling & wall R-values, when adopting 5+ star

Adelaide  11%

Brisbane  28%

Melbourne 37% 

CSIRO Report - extract pg 17

"In winter, average greenhouse gas emissions from heating appliances were reduced in higher-rated houses compared with lower-rated houses: by 50% in Melbourne, 9% in Adelaide and 13% in Brisbane. In summer, preliminary (not statistically significant) results suggest that greenhouse gas emissions may be increased for the higher-rated houses in all cities: by 37% in Melbourne, 11% in Adelaide and 28% in Brisbane.

The result in Melbourne was affected by the high emission factor of brown coal-fired power stations."

Commentary by G. Doreian

THE ENERGY GENERATED IS ONLY PART OF THE EQUATION BECAUSE IT'S NOT THE FAULT OF THE END USER HOW THE POWER IS GENERATED.

IF THE GENERATION EQUIPMENT IS OUTDATED AND INEFFICIENT, AS IS THE CASE FOR MOST OF THE POWER GENERATION IN AUSTRALIA, UPDATE THE EQUIPMENT OR USE ANOTHER FORM OF ENERGY TO PROVIDE BASELINE POWER(AFTER DARK)

IF THE AUTHORITIES ARE WORRIED ABOUT BROWN COAL, USE BLACK COAL WHICH IS MORE EFFICIENT WITH LOWER GAS EMISSIONS.

THE END USER IS WORRIED ABOUT THE COST OF ENERGY. IN BRISBANE THERE IS AN OVERALL INCREASE OF ENERGY COST OF 15%, NAMELY 28%(SUMMER) LESS 13% (WINTER). ITS WORTH NOTING WINTER HEATING IN BRISBANE IS IN REALITY NEGLIGIBLE.

AT THE "END OF THE DAY" USER BEHAVIOUR MAKES ALL THESE STATISTICS QUESTIONABLE.

Even though this Report indicates a benefit for WINTER using higher R-values, which have still have not been proven by controlled “real house” testing, the overall conclusion of this Report must be that with increasing temperatures around the world as verified in the University SA report below, higher R-values cannot be justified.

Remembering that most of the houses tested in the 2013 CSIRO Report only used R3.5 batts, and no mention if reflective foil was used under roofs.

The report says that the summer results are not statistically important.

That is ridiculous – of course they are, and in my opinion the increasing levels of bulk insulation are the likely reason.

NB: This summer information is something that the bulk insulation industry will not want to address.

CSIRO are requesting funding for further data collection and examination to repair the computer modelling program ACCURATE, and as at Feb 2014 a second Dept of Industry TENDER was issued for the task.

University South Australia

A framework for adaptation of Australian households to heat waves – 2013

specific release date unknown) 

NCCARF – National Climate Change Adaptation Research Facility, Univ SA

http://www.nccarf.edu.au/publications/framework-adaptating-australian-households-heat-waves

EXECUTIVE SUMMARY – Extract only:

* The most effective methods for reducing the cooling demand for existing dwellings is to modify their roofs by increasing their total solar reflectance, adding reflective foils and increasing thermal insulation.

See also - Section 5.3 pages 144-149, which details the case to use reflective foil under roofs in residential buildings.

The best most significant fact is that for the first time in insulation history in Australia since 1953, reflective foil is openly endorsed.

The SA report tackled many issues, but appeared not to want to address issues with high R-value ceiling insulation.

Whereas, the CSIRO 5 Star report did, which found that more bulk insulation was causing a problem with summer cooling.

Furthermore, the striking observation is that the CSIRO 5 Star report never mentioned the thermal benefits of foil, yet the SA report was extremely informative about the benefits of foil.

Before any 'works' are undertaken by any Government Scheme, the hostile roof space must be made safe, electrically safe.

What would you do if your father, son, brother, or tradesperson was killed, or seriously injured in your roof space. Ignore this, like everyone is?

Killer roof spaces, Governments Ignore

The photo above, DOR.002.005.0001 'unprotected electrical cabling over the tops of ceiling joists,' I provided with others, May 19, 2014 in the Royal Commission Home Insulation Program, and commented on by Mr Malcolm Richards, CEO Master Electricians Association UNDER OATH, IN EVIDENCE, ON THE STAND. Transcript Page 5069

BELOW Quote from Royal Commission Report Home Insulation Program 9.3.48 One of the major issues that arises when installing RFL sheeting in roof-spaces is the location of electrical cables and the extent to which they are protected . Mr Doreian urged on the Commission that long established Wiring Rules required electrical cables to be better protected from disturbance than common practice reveals to be the case.106 He produced to the Commission several photographs which showed examples of electrical cables in ceiling spaces which could only be described as chaotic.107

Photos below from ABC Four Corners Report 2010. "A Lethal Miscalculation"

http://www.abc.net.au/4corners/special_eds/20100426/insulation/

Picture above, Mr Greg Hunt, assisting an elderly constituent, standing on a ladder, looking through the ceiling man hole talking to Electrical Trade Union representative Dean Mighill regarding unsafe installation of ceiling insulation around downlights

NOTE, under Greg Hunts left arm, in FULL view of Electrical Trade Union representative Dean Mighill two unprotected wires/cables over the top of the ceiling joist in defiance of the Wiring Rules Standard. I doubt whether Greg Hunt was aware of two unprotected cables under his right elbow.

THE COVER UPGreg Hunt, as other Ministers, the Electrical Safety Offices via ERAC, the insulation and electrical industry who control document outcomes of Standards Australia, the 2014 Royal Commission and

2013 Queensland Coronial Inquiry Home Insulation Program, are aware of the unprotected cables/wires over the top of the ceiling joists revealed by myself.

Yet the Government, and everyone else is still NOT acting on the issue.

BELOW Quote from Royal Commission Report Home Insulation Program

9.3.50 It does appear that the Wiring Rules are, or in the past have not been, strictly adhered to and that this was a contributor to the electrical safety risks associated with RFL insulation. Mr Richards, for example, said that compliance with the Wiring Rules has not been actively policed for many years.109 If electrical cables are placed through joists, they are far less likely to be pierced by a staple; if they are protected either side by pieces of timber, the cable is far more prominent, and although not physically protected, far less likely to be pierced by a staple. Mr Doreian had some personal experience in his father’s building business many years ago laying timber across a ceiling joist and then clipping electrical cables to it as one way of protecting them.110

Page 202

7.30 Report ABC TV April 8, 2014 Royal Commission ref DOR.002.002.0019

From Master Electricians Association literature

The killer. 'Unprotected cabling over tops of ceiling joists' Lives are knowingly and deliberately forfeited by Governments not policing 'unprotected cabling over tops of ceiling joists' and other installation issues breaching the Wiring Rules, more so 'the motherhood' clause of mechanical damage protection of the Standard, that has not changed in over 83 years. As evidenced below, Wiring Rules Standard 1934 and 2007.

Governments failure to act exposed

If I, Graeme Doreian hadn't exposed the 'unprotected cabling over tops of ceiling joists,' during the Royal Commission Home Insulation Program, no one else would have.

Governments and the electrical industry who 'frame' Standards, being aware of their deception and endangering the public, have attempted to 'engineer' evidence to hide the truth of non - policing 'unprotected cabling over tops of ceiling joists,' FOR DECADES, AND STILL ARE TODAY.

THE REAL COVER UP

Foil radiant barriers were made the' scapegoat, the whipping' boy for everyone named above, killing those young people just doing their jobs during the failed Home Insulation Program, as evidenced by photos below.

Royal Commission ref DOR.002.002.0020

2013 QUEENSLAND CORONIAL INQUIRY HOME INSULATION PROGRAM

Photo ABOVE, the issue of unprotected cables over tops of ceiling joists in contravention of the Wiring Rules was never referenced IN ANY Queensland Electrical Safety Office REPORT.

In all the Queensland Electrical Safety Office reports, there is NO MENTION of the breach of the Wiring Rules during the installation of this foil insulation, shown above, the electrical company was never prosecuted for failing to report unprotected cabling over tops of ceiling joists in the breach of the Wiring Rules prior to the installation of the foil insulation, which covered the unprotected cabling over the tops of ceiling joists, IN TWO PLACES, in this photo.

The Queensland Coroner Mr Michael Barnes (now the Chief Coroner of New South Wales) was aware of the unprotected cabling over tops of ceiling joists by Mr James Tinslay, National Electrical Contractors Association (NECA), who was one of the witnesses that gave evidence under oath, yet the Coroner failed to clarify the issue during further questioning of that witness on the stand as revealed in transcripts, which are in my possession.

THE CORONER IN HIS FINAL REPORT:

BRIEFLY MENTIONS UNPROTECTED CABLING OVER TOPS OF CEILING JOISTS,

YET, FAILED/NEVER ADDRESSED THE ISSUE IN HIS FINDINGS OR RECOMMENDATIONS. WHY?

BELOW Quote from Royal Commission Report Home Insulation Program9.3.49 His evidence was that the installation of RFL sheeting would not be dangerous were it not for the regular and serious departure from the Wiring Rules which, as Mr Richards explained, require, at the very least since 1969 and probably longer, cables to either pass through a ceiling joist or if they pass over them, to have protections either side to prevent, for example being disturbed by kicking or inadvertent contact with feet.108 Page 202

WHY DIDN'T Mr Richards, Master Electricians Association CEO (MEA) make this admission AS QUOTED ABOVE, WHEN HE WAS GIVING EVIDENCE during the flawed 2013 Queensland Coronial Inquiry.

The revelations Mr Richards confessed on the last day of the Royal Commission Home Insulation Program, and referred to in the final report, regarding unprotected cabling over tops of ceiling joists, occurred because of Graeme Doreian photos provided to the 2014 Royal Commission Home Insulation Program, just before Mr Richards was to give evidence.

Had this 'chain' of events not occurred, my issues would have never seen the 'light of day', and basically everyone concerned would contribute to further future deaths. Simply be 'party' to murder.

Most people in politics in Australia, from the politicians to the bureaucrats, are aware I'm sure of the statement below on the entrance floor to the Victorian Parliament building, but chose to ignore this by not addressing CORRECTLY the unprotected cabling over tops of ceiling joists.

"where no counsel is the people fall; but in the multitude of counsellors there is safety"-------------------------------------------------------------------------------------------------------------------------------------

Graeme B Doreian Building Energy Consultant63 Fig Street DROMANA 3936 Victoriae mail doreians@tpg.com.au Mob 04 1987 3495

Project Based Assessments in the VEET scheme - October 2015 19 October 2015 29 November 2015

Applications for new activities and amendments to existing activities 15 October 2015 11 December 2015

Good day VEET TEAM,

not sure where these submissions enclosed should be forwarded, so I will include it in these two areas listed above for consideration.

First attached document and supporting documents

Rectify the disparity of safety procedures for the Installation of insulation and downlights.

Second attached document and supporting documents

How can insulation be considered in the VEET Scheme

Considering the dangers faced by humans entering the 'hostile war zone' of a roof space, are unresolved from the 2014 Royal Commission Home Insulation Program final report directives, via COAG.

I look forward to a written response, and meeting to discuss my submission to clarify any concerns you may have.

Could I note to all, in performing any task in a Government program or any other scenario the safety and life of humans must be paramount and anything else secondary.

Graeme B Doreian Building Energy Consultant63 Fig Street DROMANA 3936 Victoriae mail doreians@tpg.com.au Mob 04 1987 3495