Efficient Living’s founder Tracey Cools was invited to present the Assessors Perspective at the recent CSIRO Australian Residential Energy Rating Conference 2021 (ARER 2021). Tracey used the platform to share industry insights and her critical assessment of the proposed NCC 2022 policy changes.
Critical review of the NCC 2022 proposed changes
Tracey asserts Australia’s building policies are too weak and will not provide occupants with the health, comfort, energy efficiency and resilience required to withstand climate changes.
Buildings that nurture our wellbeing, enhance our health and give back as much as they take from the planet – these are the buildings of the future.
Australia’s built environment industry is seriously lagging behind the carbon trajectory required to protect life on planet earth. Everyone’s future is at stake. As an industry, we must be absolutely confident that all new buildings can operate at net zero carbon from 2030.
We need to face the fact that, many of the homes we design today will not reach 7-stars with the construction methods and typical products we currently have available in Australia.
NCC 2022 Energy Efficiency Proposed Changes: Efficient Living’s Critical Review
Watch Tracey’s speech or read it in full below.
My name is Tracey Cools, I am the founding director of Efficient Living and have been a Sustainable Building Consultant for over 20 years.
Our team has produced more NatHERS energy assessments than any other company in Australia.
Our success is not because we are cheap, it’s not because we bend the rules. Efficient Living is successful because we have committed ourselves wholeheartedly to being experts in our field.
Efficient Living is a solutions-focused organisation and we partner with our clients from the design stage through to the construction stage to ensure all their sustainability needs are met.
I have been asked to speak today to represent the voice of assessors and to give critical feedback to policymakers.
What I share with you today are industry insights as I see them.
The world is changing so fast that studies predict there will be more change in the next 6 years than there has been in the past 100 years.
This change is accelerating.
45% of jobs that exist today will not exist in the next 10 years.
Those born today will probably never drive a car.
As I sit and reflect on this I wonder:
- Are the buildings on our current drawing boards capable of evolving with the changing needs of the human race?
- Who at the design and policymaker level has been workshopping what domestic life looks like in 2030, 2050, 2070?
- Why, when we are in a climate emergency, have the home energy assessment industry and Australian building designs changed so little in the past decade?
As we sit here today, Australian policymakers have tabled the biggest energy efficiency increase in the history of residential homes in the proposed NCC 2022.
I think it’s a responsible thing to do and I believe my project home clients and my multi-unit builders will transition smoothly.
The Australian Building Codes board ran a cost-benefit analysis and has promoted to anyone naive enough to listen that this stringency increase will likely add $2000-$3000 to the cost of a new home. Suggesting a little extra insulation and performance glazing will get you there.
Today I represent home energy assessors nationally, I think it is important to say:
Your study is misleading and totally irresponsible.
Project homes do not represent the diversity in the Australian building stock. When I think about the complexities in reaching 7-star housing I think about:
- Elevated lightweight granny flat on a steep bushland block
- A heavily overshadowed terrace house in the city
- Large harbour front homes with 90% of glazing facing views on poor orientations
The truth is this stringency increase is not about calculating the extra cost to comply, this is a turning point in Australian architectural history.
We need to face the fact that, many of the homes we design today will not reach 7-stars with the construction methods and typical products we have available in Australia today.
I understand the importance of this change but transparency and industry preparation are critical keys to success.
Given the policy challenges ahead, I felt it was worth reflecting on international climate policy as a basis for comparison.
I would like to share with you some key findings from London’s Energy Transformation Initiative.
The opening statements read:
The built environment industry, is seriously lagging behind the carbon trajectory required to protect life on planet earth. Everyone’s future is at stake. As an industry we must be absolutely confident that all new buildings can operate at net zero carbon from 2030.
This is a very powerful and commitment filled statement. This is language I am not used to hearing from policymakers in Australia.
Next, I look to London’s 30-year plan for the built environment.
Step 1 : Improve cost-effectiveness through industry upskilling
This is a refreshing approach and is in stark contrast to Australia’s policymakers that have downplayed the challenges ahead.
Step 2 : Operational Energy -all new buildings designed to be net-zero operational carbon
You will then notice as we peddle around the next 2 corners of the map that we hit a flag with the year 2020.
HOLD ON! How could London’s energy strategy road map be starting where Australia’s long term policy road ends?
The truth is since Al Gore’s ‘An Inconvenient Truth’ media campaign rocked the general public in 2006, policymakers around the world leapt into climate action, setting ambitious goals.
In the past decade countries like the UK have tirelessly committed to continuous improvements to their building stock and today Zero operational carbon homes is achievable.
In Australia, policy extensions have been provided time and time again with affordability and market readiness our main reason for climate inaction.
Policy in the UK has achieved its goals with a continuous improvement approach
Now that they have net-zero operational carbon, their focus is turning to the embodied carbon within the building materials.
Australia’s classic ‘Cost-Benefit Analysis’
Given that this conference has policy decision-makers in attendance, I know you are currently sorting through piles of public submissions regarding the NCC 2022. Because of this, I think it’s worth putting affordability into perspective.
Typical hype around lack of affordability includes:
- Global pandemic
- Skills shortage
- Shortage of building materials and technologies
- Lack of education and market readiness
I reviewed CoreLogic data published in August 2021.
This data shows that average property prices nationally rose by 18.4% in the last 12 months, while in the same period the cost of construction rose by 3.9%.
This is equal to a further $80,000 in developers profit on an average Australian home.
We do not have an affordability issue and this increase needs to happen.
My key message to Australia’s policymakers
1. Stringency increases need to happen in small incremental changes
Planning policy changing in 3-year cycles might be suitable for the plumbing code but it is outrageous to maintain this cycle with Sustainability, considering the urgency required to meet Australia’s net-zero emissions goal.
The NSW BASIX team has not increased targets since 2017, they missed NCC 2019, will miss NCC 2022 and are now aiming to align with NSW SEPP in late 2022.
Zero progress in 5 years is not acceptable NSW.
Nationally, Energy Efficiency in the Construction code was watered down in 2016 and 2019 due to industry lobbying.
This was to allow time for the industry, in particular, the window industry to prepare the supply chain for the changes.
Victoria always shows leadership in Sustainability while other states have a history of climate inaction.
State policymakers if you have not prepared your local industry for this change, you have failed.
2. Less regulation does not result in better-built outcomes
The building codes are increasingly embracing performance-based solutions.
As a result of this, we have seen a rise in:
- Verification Using a Reference Building
- Non-accredited assessors
- BASIX DIY designed for mums and dads
This has opened a door to significant gaming of results and countless families living in very poor quality homes.
WA has been a classic example of this where Verification using a reference building can result in 4 to 4.5-star homes that comply with the building code.
It’s interesting to note that there are 2 window manufacturers in western Australia and neither of them produces double glazing. There is seemly no need with policy as it stands.
NSW also stands out as a huge underperformer with 81% of homes still having single glazing and the vast majority of those with regular frames and no low-E coatings.
3. Success is measured by the quality of the houses we build
All the work produced by our industry is done in the hopes that it results in a comfortable and energy-efficient home that will allow a future family to thrive.
The importance of our work is not about creating the perfect model, our models are a tool to benchmark performance.
The objective of that study is to produce a very clear set of instructions to allow a network of trades to construct a compliant building.
That’s it! Our industry’s true success can only be measured in the quality of the built product.
For the NatHERS assessors in this conference and the policymakers that do not spend time on construction sites, it’s critical that you do.
The level of knowledge, workmanship and execution of Sustainability outcomes will absolutely shock you.
If policy direction is to deliver 7-star homes you need to think about how you are going to manage that execution beyond the development application stage.
4. Empower Sustainability professionals
Our universities are producing degree and PDH qualified sustainability professionals in huge volumes.
These are the professionals trained to understand building thermal physics. Yet we struggle to get recognised as professional engineers by Engineers Australia and we can not gain registration under the buildings practitioners act.
Policy-makers, you would get a huge improvement in the built quality of homes if you mandated Certification of plans for all assessment methods, including NatHERS, DTS, DIY, or VURB
My message to consultants:
Understand and be prepared for change.
The cost and value of a NatHERS model have already plummeted in recent years as remote Australian workers and international modelling teams enter the market.
In my opening statements, I talked about 45% of jobs not existing within the next 10 years. The jobs that are disappearing are process-driven tasks that can be computer automated.
If your role in this industry is the person that completes a NatHERS assessment before plans get lodged to council this message is for you.
Policymakers are looking to empower building designers so that thermal performance becomes integrated with the design development phase.
This is increasingly important as 7-star homes become our new normal.
It has been possible to export from architectural design tools into thermal comfort software like IES and Design-Builder for many years.
Even though NatHERS Assessors will not be required to complete the base file models in the future, designers will need your expertise for:
- Data accuracy checks
- Design Optimisation
- Accurate specification of building facades
- Certification of plans
Building designers need to be across a huge number of disciplines. They cannot be experts in each field, sustainable building experts will be critical to the delivery of high performance and compliant outcomes.
Evolution of Sustainability Consultants
At Efficient Living, we decided we were not prepared to wait for policy leadership. We have changed our business model and our mindset.
We are expanding our services to allow us to work collaboratively with:
- Policy Makers to ensure appropriate and continuous improvements are made;
- Town planners to ensure subdivisions maximise solar access;
- Sales teams to give them confidence selling sustainable building upgrades;
- Building designers with support from the early concept stage to ensure floor plans are optimised, facades are correctly designed and specified;
- Marketing teams to help them achieve the best return on investment;
- Construction teams to ensure correct products are used and install methods are complaint;
- Homeowners to ensure compliance verification and support rectification works if required; and
- The supply chain to prepare for the new suite of products required to meet 7-star homes.
I am the sole Director of Efficient Living. I started this business when I was 20 years old. I do not have post-graduate degrees and NatHERS accreditation was a 2-day course when I started in this industry.
It doesn’t matter what your qualifications are what matters is: What will you contribute going forward?
At Efficient Living, we have developed a Co-Elevate program. As part of this, we are investing in mentorship from industry thought leaders, to help us and our clients rise to the challenge.
In turn, we want to help our fellow NatHERS Assessors so you can deliver the solutions and be the consultant your clients need you to be.
We are in a climate emergency
It is time to stop being fearful of your competitors
We are all driven by a desire to contribute to the climate solution
And together we are stronger
The Australian Building Codes Board (ABCB) has released a public comment draft of the proposed changes to the National Construction Code (NCC 2022).
You can access the ABCB consultation hub to review the ABCB documents forming part of the consultation process here.