HIA advocates for alternate approach and long transition period
The Australian Building Codes Board (ABCB) has been working on proposals to potentially increase the energy-efficiency provisions for NCC 2022 since 2019. This is off the back of the recommendations in the Trajectory for Low Energy Homes report that was signed off on by the former COAG Energy Council and, subsequently, the building ministers who directed the ABCB to undertake this work.
The ABCB’s work on the proposed changes is nearing completion for consideration by the ministers on the final suite of NCC 2022 changes.
HIA has been heavily involved in this work from the outset both with the COAG Energy Council, building ministers and the ABCB. We have raised concerns throughout on the potential impacts of the changes and, particularly, the further stringency changes directed at the building fabric. Another issue HIA has tackled has been the lack of a truly holistic approach to energy-efficiency requirements.
Over the past three years, HIA has worked tirelessly on reviewing and commenting on the technical provisions for all the proposed accessibility, energy-efficiency and condensation provisions. This was to ensure that the NCC technical provisions don’t go further than intended, limiting their scope of coverage, and advocating for further concessions and exemptions.
In many instances, HIA has been the lone voice in this work. It has been successful in minimising the impacts of the proposed changes that will occur on the housing industry.
Industry perspective
At the recent BMM, HIA’s executive director of building policy and services Simon Croft addressed ministers in relation to the proposed energy-efficiency changes and provided the housing industry’s perspective.
He highlighted key points:
- Consideration of energy-efficiency provisions should not be done in isolation as NCC 2022 as a whole will be the most significant amendment since the codes inception
- There is significant concern and uncertainty on the final suite of NCC 2022 changes and on timing of the scheduled adoption
- The industry is unable to fully prepare or assess the energy-efficiency proposals. The energy rating tools, which are critical to its application, are not operational, with only the least used tool available in September this year. The main rating tools will not be available until mid-next year
- An alternate 6-star plus option should be considered for NCC 2022 which allows flexible approaches to achieve a whole of home outcome
- An adequate transition period of three years or at a minimum 18 months is required, given the significance of the NCC 2022 changes.
Accessible housing and condensation provisions
The other major reforms for NCC 2022 include the new accessible housing requirements and further expansion of the condensation management provisions.
For the accessible housing provisions, the technical NCC provisions – including the new ABCB accessible (livable) housing standard – has now been settled and was recently released by the ABCB. But there’s continued uncertainty on:
- which states and territories will and won’t be adopting the provisions
- whether there will be further building exemptions and concessions enacted other than those already written into the NCC; and
- what transition period will be given for adoption of the provisions?
For the condensation provisions, the development of, and suitability of, the proposed changes has been a hotly debated topic with many alternate views expressed. The final make-up of the agreed changes are intended to be released alongside the energy-efficiency provisions.
The Building Ministers Communique did not provide further clarity on these issues and the answers will not be known until post the next Ministers meeting in July.
Transition for NCC 2022
Responding to HIA’s concerns around the significant volume of change associated with NCC 2022, the building ministers have asked the ABCB and senior officials to draft a coordinated transition and implementation plan for NCC 2022 as a whole. Ministers expect that advice to be provided by the end of June 2022.
While the ministers are taking on the industry’s concerns about the full impact of the changes and need for an appropriate transition period, the final code will not be released as a whole until August at the earliest. Deferring a decision on transition arrangements until mid-year is alarming.
This means there will be continued uncertainty for the industry in preparing their businesses for the NCC 2022 changes and on when the changes may take effect.
The BMM will meet in July when they will make the final decision on NCC 2022 energy-efficiency proposals.
HIA has expressed our disappointment on the continued uncertainty and further deferring of the decision on the final make-up of NCC 2022.