HIA advocacy on NCC 2022

HIA has said on a number of occasions that the National Construction Code (NCC) 2022 will be the largest single amendment to the building code since its inception, both in terms of the volume of changes and the significance of the changes.

There is no doubt that the timing of such substantial amendments will be concerning for the housing industry. There also remains significant concern and uncertainty on the final details of the NCC 2022 changes, including the timing of adoption by states and territories.

HIA has been heavily involved in the development process from the outset. HIA has actively engaged with the COAG Energy Council, Building Ministers and the ABCB to seek to achieve changes that are practical and measured. 

We have raised a range of concerns about the potential impacts of the changes, particularly about the higher stringency for energy efficiency and condensation provisions as well as the new accessible housing requirements. 

HIA has also tackled the lack of consideration of the cumulative impacts of NCC 2022 on new home and renovation design, and the timing of implementation when other regulatory changes are occurring at the state and territory level. 

HIA has been clear with governments - the industry’s ability to absorb all of these changes at the same time and with current stretched capacity of the industry mean that sensible transition time must be given to all of the changes in the code. 

HIA’s advocacy on the impacts of NCC 2022 major changes

HIA has been working tirelessly over the last 5 years to manage the scale and technical details in this update to the code. 

HIA has actively reviewed and suggested changes to the code, met with Ministers and heads of government departments, both Federally and at the State and Territory level, participated on the ABCB Committees and working groups and made substantial submissions outlining the impact many of the major changes will have on home building and housing affordability.

HIA has also worked to actively engage members about the proposed changes hosting a national seminar series and webinars when the draft changes and impact assessments were out for comment. HIA appreciates the many members who attended and made submissions on the changes over the last two years.

HIA’s submissions to the accessible housing proposal and Regulatory Impact Statement and the energy efficiency proposals and Regulatory Impact Statement were the most significant of any submissions. HIA has put forward members concerns and backed this up with our engagement with governments to ensure our industry’s views and voice has been heard.

This has resulted in many of the proposals not proceeding or being appropriately adjusted to require a more practical and technically sensible set of requirements. In some states and territories, we understand some of the changes will not be adopted at this time or will be varied to address the industry’s concerns. 

Our submissions to the ABCB on the other technical changes have also resulted in substantial changes to the draft provisions along with further exemptions and limiting the scope of application to a range of provisions. 

HIA is continuing to engage with the ABCB and governments to secure an appropriate transition for the adoption of the specific new requirements on accessible housing and the energy efficiency and condensation provisions.

The process to change the code is complex and time consuming. HIA has worked hard, and been the leading voice in these forums on housing issues sharing the views of members and the highlighting the practical concerns and needs for home builders and renovators. 

The voice of the industry 

NCC 2022 is not only the most substantive amendment it has also been the most contentious for more than a decade.  The changes have received significant media attention and commentary from various parties. 

HIA has publicly shared our concerns to many of the changes and outlined the significant impacts NCC 2022 will have on home building - particularly the mandatory accessible housing provisions and proposed stringency increases for residential energy efficiency. 

This has included being referenced in numerous paper and online articles and being interviewed on radio and television on a number of occasions. 

Our significant submissions to the NCC changes and to the cost benefit assessments for the accessible housing and energy efficiency changes have been quoted in many articles. 

HIA presents to Building Ministers on building industries concerns

In March this year, the national Building Ministers' Meeting (BMM) was held to discuss the proposed stringency increases for the NCC 2022 residential energy-efficiency requirements and the Regulatory Impact Statement (RIS) released last October. HIA made a comprehensive submission to this RIS.

The BMM oversees policy and regulatory issues affecting Australia’s building and construction industries.

Ahead of the BMM, an industry roundtable was held and HIA was invited, prior to the meeting, to address ministers in relation to the proposed NCC 2022 energy-efficiency changes to provide the housing industry’s perspective.

HIA addressed ministers in relation to the proposed energy-efficiency changes and provided the housing industry’s perspective and highlighted the following 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 proportional to the significance of the changes is required for industry to prepare their businesses to the NCC 2022 changes.

HIA was also invited and presented at the November 2021 BMM and highlighted similar concerns to Ministers.

Following the March BMM, HIA was requested to put forward a transition proposal for the accessible housing, energy efficiency and condensation provisions. 

HIA advocated, as we have on a number of occasions, for a full three (or a full NCC amendment cycle) transition or at a very minimum of 18 months is required (meaning adoption 1 May 2024), given the significance of the NCC 2022 changes.

Responding to HIA’s concerns around the significant volume of change associated with NCC 2022, Building Ministers have requested the ABCB and senior officials draft a coordinated transition and implementation plan for NCC 2022. Ministers expect that advice to be provided by the end of June 2022 and industry to be notified of this after the next BMM meeting in early July.

HIA successful in getting a range of positive NCC 2022 changes

Among the raft of significant and far-reaching NCC 2022 changes, HIA has been leading the charge on improving current reforms through the NCC and Australian Standards. 
These reforms will minimise the impacts and get positive reforms for members and the residential building industry.

The upcoming changes include a range of amendments that industry has been calling for over a number of years. They will also provide more compliance solutions for builders, designers and product manufacturers.

Some of these issues, for example on external walls and cladding compliance for Class 2-9 buildings, has resulted in non-approvals, need for costly and time-consuming Performance Solutions and uncertainties, disagreements and disputes. 

Many of these have derived from relatively straightforward matters. However, the lack of NCC clarity and a risk aversion for acceptance of anything that’s not explicitly prescribed has resulted in voluminous email chains. This halted many projects in the process and added unnecessary costs.

HIA was successful in advocating for a range of changes to overcome these issues and to provide greater certainty for the industry and these amendments should provide some welcome relief. 

For Volume Two, the changes will also provide greater certainty of compliance, and make the provisions more useable. The changes include:

• New Deemed-to-Satisfy Provisions for waterproofing of internal wet areas, similar to those previously in BCA 1996-2010 
• New Deemed-to-Satisfy Provisions for double brick and single-skin masonry 
• Revised gutter and downpipes, slabs and footings, heating appliances and attachment to decks and balconies. 

Alongside these amendments, HIA progressed a range of changes throughout Volume One and Two and in a range of Australian Standards including: 

• Introduction for the first-time DTS Provisions for certain wall cladding materials for Class 2-9 buildings 
• Transitional periods to a range of changes 
• Revision of acceptable BMT thickness for metal framing 
• Clarification changes to the waterproofing and masonry for small buildings standards including expanding on acceptable solutions 
• Overcoming ambiguous drafting on the application of external waterproofing provisions 
• Interpretational issues in a number of areas of the code 
• Limiting the impact on a range of new NCC changes and the scope of application.

More information on NCC 2022 and HIA’s advocacy

HIA has produced a range of information resources and videos to support members in preparing their businesses for NCC 2022. 

View HIA’s submissions to the NCC 2022 drafts and the regulatory impact assessments. 

There is also a range of articles that we have published over the last 3 years in our Housing publication under Industry focus on HIA’s advocacy and in keeping members abreast on the NCC 2022 changes.

To find out more, contact HIA’s Building Services team.

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