Response 642791737

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Personal Information

What is your name?

Fred Batterton

Please select your State or Territory

Please select one item
ACT
NSW
NT
Qld
SA
Tas
Vic
WA

What is your organisation? (if applicable)

Studio B Architects

Which best describes your industry sector?

Please select one item
Building Commercial
Building Residential
Building Commercial and Residential
Building and plumbing products
Building Certification/ Surveying
Architecture and design
Engineering
Plumbing
Compliance, testing and accreditation
Legal and Finance
Specialist - disability access
Specialist - energy efficiency
Specialist - fire safety
Specialist - health
Specialist - hydraulic/ plumbing
Student/ apprentices
Trades and other construction services
Education
Community and Non-Government organisations
Government
General Public
Other

Statement of the problem

1. Does the CRIS adequately identify and define the problem?

Please select one item
Yes
No
Unsure
If you would like to expand on your answer, please do so below
It does not go far enough. We could be much more energy efficient.

2. Are there any other problems not considered by the CRIS?

Please select one item
Yes (please explain your answer below)
No
Unsure
Please expand on your answer below
Future proofing for climate change. Imposing high running costs on the rental sector by not requiring better energy efficiency at the point of construction. Improving ventilation to reduce the risk of airborne transmitted disease.

3. Does the CRIS establish a case for amending the energy efficiency provisions of the NCC?

Please select one item
Yes
No (please explain your answer below)
Unsure

Objectives and options

4. Does the CRIS present clear, well differentiated options for amending the NCC that can achieve the stated policy objective?

Please select all that apply
The options are clear
The options are well differentiated
The options can achieve the stated policy objectives
None of the above statements are true
Please expand on your answer below
The policy objectives are weak.

5. Which of the options analysed have the ability to meet the stated objectives?

Please select all that apply
Option A
Option B
The status quo
None of the options
Unsure
Why did you make that choice? And how can the options be enhanced?
The criteria being considered too narrow. We should consider the regulatory frameworks being adopted by Vancouver, Brussels and others which have a clear pathway to Passive House standards which cover comfort, running cost, ventilation, CO2 emissions, hygiene, orientation and construction efficiency.
Rather than trying to painfully turn the screw for better standards every three years we should plan towards a known standard that can target a zero carbon future and create the stages to get there.

6. Are there any other feasible options to address the problems identified in the previous chapter that have not been assessed in the CRIS and should be considered?

Please select one item
Yes (provide detail below)
No
Unsure
Please provide as much detail as you can on other feasible options
See my response above

7. Of the options discussed in this chapter which would be the most effective at achieving the stated objectives and why?

Option A Option B Status quo Unsure
Option A Option B Status quo Unsure

8. Which is your preferred option? (Answer required)

Option A Option B Status quo Other
Option A Option B Status quo Other

9. What should the objectives of the residential energy efficiency provisions of the NCC be?

Please select all that apply
Reduce energy use
Reduce greenhouse gas emissions
Improve occupant health and amenity
Improve the resilience of a building to extreme weather and blackouts
Other
If you selected other, type the objective(s) here
comfort, running cost, embrace available natural resources, minimise habitat destruction and require green lung amenity.

Framework for analysis

10. Are there any assumptions or parameters used in the analysis that should be different?

Please select one item
Yes (please provide details below)
No
Unsure

11. Should thermal bridging in timber-framed buildings be incorporated in the analysis?

Please select one item
Yes (please explain how below)
No
Unsure
Please expand on your answer below. How should it be incorporated?
This is not only important for energy efficiency it is also important for hygiene (to avoid the potential for mould growth)

12. Is it reasonable to assume that industry’s response to the proposed changes will be to select the lowest cost alternatives in every case?

Please select one item
Yes
No (please expand on your response below)
Unsure
Please explain your answer below
We need a pathway to Net 0

13. How would industry most likely respond to the proposed whole-of-home changes under each of the proposed options?

Install what is cheapest to meet the requirements (the cheaper of more efficient appliances or PV) Continue to install the same equipment and install PV (to meet the energy budget) Continue to install the same equipment and improve the thermal shell Switch to using a performance solution Other - please explain below Unsure
Install what is cheapest to meet the requirements (the cheaper of more efficient appliances or PV) Continue to install the same equipment and install PV (to meet the energy budget) Continue to install the same equipment and improve the thermal shell Switch to using a performance solution Other - please explain below Unsure

14. How would industry most likely respond to the proposed thermal fabric changes under each of the proposed options?

Substantially maintain existing home designs, and improve the performance of materials like insulation and windows Change building designs – reduce window sizes Change orientation of living rooms within the home Switch to using a performance solution Other - please explain below Unsure
Substantially maintain existing home designs, and improve the performance of materials like insulation and windows Change building designs – reduce window sizes Change orientation of living rooms within the home Switch to using a performance solution Other - please explain below Unsure

15. In some cases, smaller windows are assumed to be used to constrain costs or achieve compliance with the proposal. Should the impact on occupant amenity be valued and how?

Please select one item
Yes
No
Unsure
Please explain your answer below. How can this be valued?
Passive house quality windows can equal the thermal performance of insulated walls. Yes there is a cost but smaller windows need not be a loss of amenity.

16. Does the use of a high efficiency equipment solution as a proxy for other non-modelled solutions over/under-estimate the costs of the proposed changes for Class 2 dwellings?

Please select one item
Yes - costs will be higher than those in the table
Yes - costs will be lower than those in the table
No - costs will be similar to those in the table
Unsure

17. Does the above proxy over/under-estimate the benefits for Class 2 dwellings? If so, by how much?

Please select one item
No
Yes - over-estimates the benefits
Yes - under-estimates the benefits
Unsure

18. Is it practical to apply the whole-of-home proposal to refurbishments?

Please select one item
Yes
No
Unsure
Please explain your answer below
Passive house has a process for certifying a renovation plan in stages to eventually reach a high standard. This should be encouraged in order to create a future sustainable long-term building stock.

20. Would the cost of applying the whole-of-home proposal to renovations be broadly similar to the cost incurred in new dwellings?

Please select one item
Yes
No - costs higher in renovations than new dwellings
No - costs lower in renovations than new dwellings
Unsure

21. Would the benefits resulting from applying the whole-of-home proposal to renovations be broadly similar to the benefits received by new dwellings?

Please select one item
Yes
No - benefits for renovations lower than for new dwellings
No - benefits for renovations higher than for new dwellings
Unsure
Please explain your answer below
The risk of applying to whole of home is that you achieve an interim standard in 2023 that needs to be upgraded again in 2033 which is likely to involve destruction of some of the lower standard improvements from 10 years earlier. Much better to have a staged approach such as Stage-by-Stage EnerPHit by Passivhaus.

22. Are the assumptions used to estimate current and future penetration of solar PV in new buildings under the BAU appropriate?

Yes No - please state why below Unsure
Yes No - please state why below Unsure

23. Do you have any information that could be used to estimate the proportion of blocks for which solar PV could not be installed?

Please select one item
Yes (please provide this information below)
No

24. Do you have any information that could be used to estimate the proportion of Class 2 apartments for which sufficient solar PV could be installed to meet the energy use budget of each individual apartment?

Please select one item
Yes (please provide this information below)
No

25. As noted in this chapter, expected decreases in feed-in tariffs would effectively increase the stringency of the proposed whole-of-home requirements under Option A over time. Do you have any views on this issue?

Please select one item
Yes (please provide your views below)
No