The NSW government quietly released public submissions to proposed changes to the Building Sustainability Index last month, which has recommended improving water and energy consumption targets for new houses and residential apartments.

Opposition came from the likely quarters of the industry, with Master Builders Association and the Housing Industry Association both opposing the move, along with a number of developers, including Meriton.

Councils, sustainable home builders and green bodies generally welcomed strengthening of targets, with many pushing for more to be done.

See our previous articles:

Out of the 83 submissions received from individuals, councils, government agencies and industry stakeholders, most –57 per cent – supported the proposed changes, which will see energy and water efficiency in new homes by around 10 per cent for detached houses, attached houses and low-rise buildings, and five per cent for mid-rise building. A minority of 13 per cent opposed the changes, while 30 per cent did not state a position, but suggested amendments.

Of those with a stated opinion, 81 per cent were in favour.

As discussed in a previous article, a higher water target was a key issue, with many raising concerns that rainwater tanks of 8000 litres would be needed, and would be unwieldly for many properties.

What those in favour said

Australian Institute of Architects: “We support the new [BASIX] target proposed in the review, which we recognise as a pragmatic response to the current state of the housing construction industry, consumer sentiment and technological improvements over the last decade… In the Institute’s view, NSW needs to ramp up its commitment to energy efficiency through a commitment to zero carbon homes and complementary targets for commercial buildings and general industry emissions.”

Flow Systems: “Flow Systems welcomes NSW Planning & Infrastructure’s proposal for a BASIX 50 [50 per cent above NSW average benchmark] target. We believe the economic benefits exceed existing benefit-cost scenarios when water recycling is the key driver, not rainwater tanks.”

Green Building Council of Australia: “The GBCA supports these changes and believe they will have a greater impact upon reducing greenhouse gas emissions from the built environment. With regards to the proposed increases to water efficiency targets and policy changes, the GBCA believes the changes will also have a considerable impact to reducing potable water use. As can be seen by the benefit–cost analysis completed by The Allen Consulting Group, the proposed changes can result in increased water and energy efficiency, all the while delivering a benefit–cost ratio to the NSW economy of 1.64.”

Integreco: “We strongly support the increase of the targets for energy, water and thermal performance and believe they are technically and economically feasible. They will increase the dependence on passive and design principles (rather than “end of pipe” last minute, technology or product-based solutions that always increase costs) to minimise cost of implementation and therefore are likely to improve the efficiency of design and construction overall.”

Total Environment Centre: “We consider that the proposed reforms are generally worthwhile but are unambitious and should go much further. In particular, the targets for medium density dwellings – the majority of new housing stock – remain mediocre.”

Willoughby Council: “WCC generally supports any increase to the BASIX targets however the revised targets still appear to be too lenient.”

Against

Housing Industry Association: “The Benefit Cost Analysis prepared by the Allen Consulting Group fails to make out the case for changes to the BASIX targets. HIA has identified a number of matters that we believe are errors in the analysis… On this basis, it is not considered that the changes will meet NSW’s obligations under the National Strategy on Energy Efficiency, which requires a positive cost benefit… It is considered that at this point in time, the status quo of 40/40 targets should be retained to help give certainty to both industry and consumers.”

Integrity New Homes: “At a time when costs of construction are already being driven higher by a carbon tax, safety requirements and ever increasing council rules and regulations the construction industry does not need such hefty additional costs.”

Master Builders Association of NSW: “Increasing these targets will directly impact on housing affordability and provide little net benefit to improving water and energy efficiencies… This is not the right time for industry or consumers to implement the proposed changes.”

Meriton: “We applaud the efforts of the government in this area and recognise the substantial water/energy savings made through BASIX since implementation, however, we do not support the increase in targets. The fundamental basis for our opposition is associated with the respective increase in construction costs that ultimately passes on through to housing prices and that the BASIX system is already making significant contributions.”

Some concerns

The Property Council of Australia said it supported BASIX, but said the proposed changes would lead to “over-regulation”and would reduce flexibility for building innovation and design. It recommended a suite of alternative solutions to increase building sustainability.

Country councils like Albury appeared hesitant, saying there was a lack of detail available regarding costs to local communities, and a lack of consultation. The Allen report, it said, found costs of up to $8000 a dwelling in Wagga Wagga, with savings of only $7000 over properties’40-year lives.

Armidale, meanwhile, said changes hadn’t gone far enough. It said double glazing should be made mandatory in cold climates, and that the review should have been expanded to include passive design, solar access and building material considerations.

Read all the submissions.