SUBMISSION BY THE AUSTRALIAN CELLULOSE INSULATION MANUFACTURERS ASSOCIATION (ACIMA) TO The Federal Minister for the Environment RE VENTED RECESSED CEILING LIGHTS' (VRCL) NEGATIVE IMPACT ON RESIDENTIAL BUILDING ENERGY EFFICIENCY IN AUSTRALIA July 2008 1. Executive Summary 1.1 The following submission by the Australian Cellulose Insulation Manufacturers Association (ACIMA) seeks Local, State / Territory building & Federal Government regulators' intervention to overcome vented recessed ceiling lights (VRCL) current substantial negative impact on residential building energy efficiency measures in place throughout Australia. 1.2 By way of background, ACIMA represents those cellulose insulation companies who manufacture and supply more than 80% of Australia's cellulose insulation to the annual $650 million national insulation market. 1.3 Central to the quantification of VRCL's contribution to the loss of building energy efficiency, is a need for the urgent review of the current disputed method for estimating, via the CSIRO/Commonwealth Department of the Environment-developed Accurate 1.1 software, VRCL's negative impact on residential building energy efficiency nationally. 1.4 ACIMA believes that there has been insufficient investigation of the fact that VRCL substantially reduce advertised personal comfort levels to occupants and $ savings to homeowners, due to VRCL's contribution to the significant loss of residential buildings' conditioned air. 1.5 The potential positive impact on residential energy efficiency of ACIMA's proposed VRCL insulation cover in the current approximately 1 million Australian homes who have VRCL & insulation, is far more significant than say, if those homes exchanged their 70 Watt light bulbs for 7 Watt bulbs. 1.6 With the Federal Government's planned late 2008 launch of its national insulation subsidy retro fit campaign for 300 thousand rental properties, it's important for local, State & Federal government building energy efficiency regulators to address this serious problem now. 1.7 A campaign for the retro-fit of the a VRCL cover should also be pitched at those 1.2 million Australian homes with VRCL currently installed. 1.8 With the current review of bulk insulation installation standard AS3999 due for completion early in 2009, the introduction of an insulation cover rating should be included in the new standard. . 2. Vented Recessed Ceiling Lights (VRCL): Key Issues 2.1 The current widespread use of non-enclosed VRCL in residential housing Australia-wide that are not enclosed, results in a significant loss of conditioned air. 2.2 Vented recessed ceiling lights (VRCL) reach high operating temperatures which in accordance with the AS/NZS 3000: 2007 Wiring Rules, requires that insulation installers install thermal insulation with a 200 millimetre clearance to avoid a fire hazard. 2.3 There is also a risk of a VRCL failure if it is surrounded with thermal insulation. The risk of fire is increased with all types of thermal insulation as the resulting higher temperatures can ignite timber framing. 2.4 The AS 3000: 2007 Wiring Rules requirement of large clearances around VRCL, create the problem of thermal bridging, which eliminates or substantially reduces the installed insulation performance. 2.5 The resulting substantial reduction of the intended R-value of the building structure, makes a mockery of both: · the advertised comfort levels and $ savings to homeowners via building energy efficiency measures Australia-wide, and · the contribution of the national residential sector to greenhouse gas reduction targets. 2.6 There is a also an urgent need to open the current AccuRATE 1.1 energy ratings software for public comment in order to accurately assess the method currently used to establish the extent of this loss. 2.7 Each recessed light has an equivalent air leakage area of 10 cm² [ASHRAE]. This air leakage area though much smaller than the uninsulated area [2][3] is considerably more significant [4]. 2.8 The effective R-value alone does not determine if heating or cooling is required as a combination of both R-value and latent heat are required to regulate building temperature in the absence of artificial heating or cooling. 3. The Solution 3.1 As a matter of urgency, Standards Australia EL/1 Wiring Rules Committee should recommend the introduction of a VRCL insulation cover rating via AS 3000, to be followed by the mandating of the rating by State/Territory governments for all new residential buildings in Australia. 3.2 At the same time, a consumer education campaign for retrofit of the cover should be pitched at those 1.2 million Australian homes currently with VRCL & insulation. 3.3 This would address both the aforementioned thermal bridging and air infiltration issues. 3.4 An insulation cover rating would also be consistent with partially surrounded wiring in AS/NZS 3000 where heat can be dissipated through the ceiling. 3.5 It's important to note that the impact on residential energy efficiency of an Insulation Cover over a VRCL is far more significant than, say, if 70 Watt residential light bulbs were replaced with 7 Watt bulbs. 3.6 In the U.S. builders must ensure that recessed lighting fixtures installed in the building envelope be Type IC. The latest version of the US Model Energy Code, 1995 edition (Chapter 5, Section 502.3.4 and 602.3.3 - Recessed Lighting Fixtures), specifies that recessed lighting fixtures installed in the building envelope must be "Type IC." 3.7 Also, the Insulation Contractors Association of America (ICAA) recommends that only Type IC recessed lighting fixtures be installed in the building envelope, and that Type IC fixtures should be used wherever ceiling insulation is present. 3.8 Type IC Recessed Lighting Fixtures are selected for their safety, energy efficiency, and utility. e.g. since IC recessed fixtures can be covered with insulation, they reduce energy loss. 4. Summary 4.1 The current widespread use of VRCL in residential housing Australia- wide which are not enclosed, results in a significant loss of conditioned air. 4.2 Federal. State & Local Government regulators & Standards Australia should urgently review the current regulations regarding installation of vented recessed ceiling lights (VRCL) 4.3 Both air-infiltration and thermal bridging effects need to be addressed. Application of insulation has a direct result on thermal bridging. The combination of air-infiltration and thermal bridging are significant factors in how a building responds to temperature changes. 4.4 For further technical background outlining ACIMA views on VRCL, please visit our website www.acima.asn.au 4.5 ACIMA wishes to participate as an expert member of any regulatory review mechanism. ends .