Consultation RIS - Proposed NCC 2022 residential energy efficiency provisions

Currently there are lobby groups that represent builders that resist greater regulatory control. The Regulator effectively is an arm of Government and are influenced by industry (c.f. Crown Casino and its relationship with the Government Regulator), the Government makes more out of construction than anybody and so has a vested interest in nothing upsetting the powerful lobby groups representing both builders and the suppliers of building materials.

The Energy Star Rating system has failed the home owner since it is largely a "box ticking" exercise with no empirical testing. If we are to see any real improvement in the thermal efficiency of our built environment we have to rapidly move to physical testing (e.g. Blower Door Testing). This is the ONLY "stick" that works in terms of independent scrutiny. Any situation where building inspection is carried out by nominated practitioners of the builders is verging on the ridiculous (personal example is where an Occupancy Certificate described the property as being a 3 storey townhouse, when it was only 2).

Buildings have to be looked at holistically as a complex set of interacting systems. If tehy don't work in harmony and are not designed to work in harmony then how can they possibly be optimal? It is like an animal being designed by a committee.

My area of expertise and interest is pressure sensitive tape technology. I work for a small independent fourth generation family business that sources specialised pressure sensitive tapes from over 40 companies around the world. I read recently in some comment from the ABC that "in Australia we live in tents" yet the article then completely failed to address this issue and talked about alternative sources of power generation. If we are to meet the new targets required by 2050 in Carbon Emissions then clearly we have to seriously address the demand side of the equation and build more energy efficient homes.

As I have a vested interest in pressure sensitive tapes I am biased in my view but it seems from all I read and learn in other countries that, until we learn to keep the air that we have spent money and expended energy to "condition" (heat in winter and cool in summer) inside the building, then we are singularly failing the most basic of tests. In the human body the skin is the largest organ and in a house the wrap is the functional outer membrane - any outer cladding is akin to clothes (it protects against the elements and is often aesthetic in nature). So, if we cut our skin we bleed and if we leave holes or gaps in the building's functional membrane it will bleed the conditioned air (often and commonly more quickly than we can pump it in). The impact is that the heating or cooling runs continually and just turning the thermostat down a degree or two may have little impact if the building is not sealed and the correct wraps have been used to allow the building to "breathe" - let water vapour escape to the outside but stop moisture entering the building and affecting insulation and other structure and services leading to rot.

If you are going to seal the building then this will require the use of mechanical fasteners or glues but, more commonly, some form of pressure sensitive tape is used. Since once applied all this is hidden from view it is seen as an area where savings can be made (out of sight, out of mind). In a competitive market builders struggle to make a margin and so once a contract has been signed any way that cost can be reduced is profit to the builder and so areas such as insulation and sealing is seen as a prime opportunity to save since nobody can check. However if the wrong tapes are used they may either never form a functional seal or the adhesive systems oxidise and then with any building movement fail in a short space of time. The difference between using a tape that is fit for purpose and will last, say 50 years and one that is not is minimal in the overall cost of the build. However it is utterly pointless paying for expensive glazing if not installed and sealed correctly as the conditioned air just bleeds around it and so it's thermal values become pretty meaningless (as stated, these are complex systems that must be addressed holistically).

The real issue comes with determining what tapes are fit for purpose and which are not. This is hugely vexed but the Japanese are trying to create a Standard for sealing tapes and the problem is that the test regime used for assessing products must have scope of testing longevity over extended periods (there is always a trade-off between the adhesive (stick) strength of a pressure sensitive and cohesive (internal strength of adhesive). The problem here is that the people who supply the market will lobby to have any Standard written around their products to try and exclude others and protect market share and so people, such as myself who have products that are relevant are biased. So, it would be naive to think that this is easy but it does require further investigation and is why Building Guarantees for a reasonable period of at least 7 Years and Blower Door testing may be the best way of ensuring that builders do their research and only use tapes that are not likely to leave them exposed (or use contractors that know and understand the issues and are willing to warrant the work for a required period).

This seems to be an area that few want to address yet may represent the biggest opportunity to quickly improve the energy efficiency by reducing the air exchanges per hour in a building.

As I have little knowledge or experience in this area I don't feel any comments are of great value to you.

Not qualified to offer a valid response