In the last week of work before Christmas, the report from Phase 2 of the National Energy Efficient Building Project was released.
Just as with Phase 1 in 2014, we were assured the timing was not to minimise coverage. Back then the findings were damning – “a pervasive culture of mediocre energy performance across the Australian building industry” – so we had our doubts regarding the release date.
This time the findings are less incendiary, but point to a widespread lack of documentation and ability to accurately assess compliance with the National Construction Code.
Phase 2 pilot projects were created to further investigate the issues raised from Phase 1, particularly in the residential construction sector, where non-compliance is rife. Exciting is that these pilots could pave the way towards mandatory as built inspections and an electronic building passport system to increase accountability and adherence to energy requirements of the NCC.
Project 1: As built inspections
Due to the widespread non-compliance in the residential market, the first project of Phase 2, the New Home Energy Efficiency Compliance Inspections Project, involved developing and piloting an “as built” inspection process to check compliance against energy efficiency provisions in the NCC.
An inspection checklist was developed, and 86 inspections completed on 59 homes by nine councils across Australia in a range of different climate zones and jurisdictions. The checklist aimed to assess compliance at two points in the building process (typically a post-frame inspection and a near-final inspection).
Compliance varied across jurisdictions, however only a small amount of homes were deemed to be non-compliant.
Identified areas of non-compliance included:
- Roof colour not as specified
- Insulation not as specified
- Insulation not included under flooring (where specified)
- Insulation not installed in accordance with the NCC
- Alternative lighting installed by owner not as specified
- Glazing not as specified
- Inadequate sealing of glass/windows
However, throughout the pilot phase there was difficulty in assessing as built compliance, with more than half of homes (30 of 59) not able to be marked as compliant or non-compliant. This was due to areas yet to be completed or unable to be visually assessed.
The pilot project found there were various elements needed to enable verification of compliance at the as built stage, including:
- provision and access to verification documentation such as insulation/window certificates and purchase details, photographic evidence from builders etc
- appropriate timing of inspections so items such as roof insulation, glazing type and wall insulation can be physically inspected after installation but before being concealed
- adequate information at the approval and energy assessment stage – in many areas, compliance could not be measured due to lack of information provided in the development approval documentation, most commonly roof colour not specified, lighting type not specified, airconditioning not specified and hot water not specified
While the councils involved recognised the benefits of an as built inspection regime, if it were to work successfully, councils participating in the pilot said support was needed through:
- improved design assessment and documentation
- verification of product performance through documentation
- professional development and training for building surveyors
The report made a number of recommendations regarding the next steps for trialling and developing compliance inspection resources, and the system elements needed to support as built inspections, including:
- the development and application of model code provisions and/or regulations to guide an inspection regime, incorporating a nationally consistent audit quality framework and an approach to evaluating inspection performance
- integrating the NCC provisions and checklist elements into mandated inspection stage guidelines and resources
- Undertaking a more in-depth review of the costs, benefits and limitations of complementary compliance models in consultation with authorities and Industry
- moving from a pilot to a voluntary trial, which would also enable integrated testing with the Electronic Building Passport product as well as the new NatHERS certificate (project 2, below)
- Incorporating the inspection resources and guideline into an accessible online knowledge platform for building surveyor professionals and other stakeholders
- Developing awareness raising information on the opportunities and benefits of compliance with NCC energy efficiency requirements
- Providing incentives for an accredited professional development program on energy efficiency for stakeholders, industry and councils and advocate for a mandated system for as built inspections
- Support a national social marketing campaign to educate consumers, home owners/purchasers and the real estate industry, about building energy efficiency
See the full report.
Project 2: Electronic Building Passports
One issue flagged in Phase 1 and explored in The Fifth Estate is the idea of Electronic Building Passports – an efficient, low-cost and secure system for managing access to building documentation in a bid to improve accountability, compliance and a consumer “information asymmetry” regarding the quality and sustainability of residential housing.
The EBP project was undertaken by pitt&sherry and a Queensland University of Technology team led by Dr Wendy Miller.
A building passport would allow all stakeholders access to key documentation needed to verify building energy performance. The functionality of the tool would include the ability to:
- store all documents related to compliance with the NCC, state regulations and council requirements on energy efficiency
- permit controlled access to documents for individual properties
- allow updates of datasets for specific buildings – for instance when the building undergoes renovation, or a new approval point is reached
- allow users to select particular information and files/documents (for instance where documents for an audit process are wanted) by property
The researchers recruited nine councils to help develop and trial the building passport system, and to assess the extent to which the councils were currently utilising documentation. It was found, however, that no council was compiling all of the energy performance-related documentation needed to demonstrate code compliance.
Key reasons included:
- a major lack of clarity on precisely what documentation should be collected
- cost and budget pressures
- low public/stakeholder demand for the documentation
a pragmatic judgement that non-compliance with any regulated documentation requirements represents a relatively low risk
“Overall we formed the view that documentation and information tracking processes operating within the building standards and compliance system are not working to assure compliance with the code’s energy performance requirements,” the executive summary stated.
“In other words the code, and its implementation under state and territory regulatory processes, is falling short as a ‘quality assurance’ system for consumers. As a result it is likely that the new housing stock is under-performing relative to policy expectations, consuming unnecessary amounts of energy, imposing unnecessarily high energy bills on occupants, and generating unnecessary greenhouse gas emissions.”
The report noted a number of problems in the current system, including:
- Poor consumer understanding of energy efficient homes
- Lack of consumer understanding of the regulatory system
- Non systematic collection and use of energy efficiency related information
- Unclear accountability and responsibility for information collection and storage
- Privacy concerns
- Weak enforcement
- Product substitution
- Lack of “pull policies”
- Regulatory and market weakness in combination
An EBP could fix some but not all of the problems, and could be considered as “one of the foundation stones of a quality assurance system for housing in Australia”, through:
- Reduced compliance costs via electronic document lodgement and storage
- Allowing information to drive value chains
- Improved documentation accountability
- Facilitating audits and improving compliance
- Making use of current technologies and reducing compliance cost
- Facilitating voluntary disclosure, building verification and other best practice initiatives
- Improved national consistency, reducing regulatory uncertainty, boosting competition
- Spill-over benefits – build quality, safety and comfort
- Improved statistical information for policy development
To enable the development of a nationwide electronic building passport, the authors made a number of recommendations, including:
- Integration of the electronic building passport and the residential energy efficiency as-built audit process, including the appointment of an EBP and audit protocol expert committee to steer EBP and audit process development
- The development of guidelines that include minimum documentary requirements to be held within the EBP and also set the minimum requirements for meta-data field completion
- The expert committee should open a dialogue with relevant stakeholders (including ALGA, AIBS, ABSA, ASBEC, Standards Australia, ABCB, CASBE, etc) regarding optimal and collaborative implementation solutions for an EBP
- Conduct pilot testing of the new EBP and audit protocol and updated tool and new applications with councils, private certifiers and builders
- Commence development of a national compliance framework that clearly explains the whole NCC and regulatory compliance system, and the role of the EBP and Audit protocol within that system
“Overall, we conclude from this pilot that the public good would be well served if the Australian, state and territory governments continued to develop and implement an Electronic Building Passport system in a cost-efficient and effective manner,” the report said.
See the full report.
The next steps in the process will involve using the findings from the pilot projects to work with building regulators and industry energy efficiency advocates, the Australian Building Codes Board and other key building industry bodies to improve capacity to monitor, enforce and implement the energy efficiency requirements of the NCC.