It’s too vague, has no aims, is riddled with loopholes and appears to have abandoned any explicit imperative to make a building energy-efficient or sustainable – it’s a new lower-bar Building Code of Australia 2016.
Some of the proposed changes to the National Construction Code are so dodgy, the new modelling protocol would allow an apartment that scored ZERO NatHERS stars under the old system to actually pass as compliant, leading ESD practitioners say.
These are some of the concerns about the proposed changes to the NCC that have brought 17 of Australia’s leading sustainable design and construction experts together to form a united response to some of the issues around Section J, which sets out the minimum requirements around energy and thermal performance.
The ABCB says it welcomes “the opportunity to discuss with any industry group the proposed changes and the separate matters of increasing the stringency of the requirements and the broader topic of sustainability”. ([See the full text of the response below.)
Among the flaws they have identified in the proposed changes are:
- too many loopholes in proving compliance
- failure to promote improvements to the performance of buildings
- an overall lack of vision that could see Australia become uncompetitive in world terms
The group has developed a website, and will post its commentary on Section J this weekend ahead of making a formal submission to the Australian Building Codes Board. The hope is that others concerned about the sustainability of our built environment will also be able to use the information to inform their own submission to the NCC 2016 consultation.
The comment period closes on 3 August.
Another consideration that has got the members of the group fired up is that the final NCC 2016 will move to a three-year code amendment cycle, instead of an annual amendment cycle.
Chris Buntine, ESD Leader for Aurecon Melbourne told The Fifth Estate there was a “sense of frustration”.
“We’re running out of time to get this right.”
Mr Buntine said the ABCB could have been having the sustainability conversation already, but that “the voices about red tape and cost seem to be winning”.
“This is about having a leading edge, innovative industry, but we are not being heard.”
Jeff Robinson, sustainable design leader Asia Pacific for Aurecon, said that in the context of greening the built environment, the focus of the industry needed to be on how to design buildings that use fewer resources to build.
This, he said, was one of the cheapest ways for the nation to reduce its carbon emissions and deliver increased productivity outcomes, and better health outcomes, for people using the buildings. This new iteration of the NCC, however, is not taking the industry in that direction.
Mr Robinson said members of the industry group are modelling the different types of buildings including commercial and multi-residential under the revised Section J Performance Pathway rules to inform their submission. Some of the results are alarming.
Decades of experience ignored
And while there is decades worth of expertise in the group in high performance buildings that could be very useful to the ABCB, he noted that the board is restricting all those commenting on the NCC 2016 to only addressing the proposed changes and the language of the new code. There is no scope for going beyond to make a broader contribution, which he said means it is “not a genuine consultation”.
“We can’t give our opinion [on other matters],” Mr Robinson said.
Mr Buntine said the ABCB and the wider industry needed to be looking at sustainability more broadly, not only energy, but also water, waste, wellbeing and health. This type of holistic approach to buildings, however, is not in the code.
“[The code] needs to pull together in a way that promotes an integrated solution,” he said.
Mr Robinson said that while there have been some genuinely good improvements over the years in the Building Code of Australia, in this latest version “the foot has been taken off the stringency accelerator”.
“It doesn’t lift minimum standards. It is following the path of least resistance.”
But the industry group is looking for continuity with the standards of NABERS and Green Star. The NCC 2016 is not even close to those standards.
The gap between best practice and the code makes it harder to justify the investment in higher performance to clients, he said.
“The reality is the world only has so many resources, and if we are [for example] designing great apartments, we are also making an investment in the infrastructure of our country.”
He said the quality of life Australians took pride in was also at stake, and that without an emphasis on designing and delivering more sustainable buildings, “other nations will overtake us”.
“We’re sliding backwards.”
Mr Buntine said many of the members of the group belonged to industry associations such as Australian Institute of Architects, Engineers Australia, AIRAH, Consult Australia and the Property Council, and it was hoped these bodies would support the push for stronger sustainability in the code.
There was no commercial incentive or vested interest in the group’s push, he said.
“We get paid the same amount whether we analyse poor buildings or good ones.”
Cormac Kelly, sustainability project engineer at Wood +Grieve Engineers, said that while some elements of the proposed changes were “encouraging”, there were also numerous loopholes.
These loopholes would allow buildings to show they complied, but not necessarily as well as any intent the code may have to ensure a basic level of energy efficiency.
“It’s not tied down tight enough,” Mr Kelly said.
Code needs a higher bar in energy efficiency and thermal comfort
There is also a need to raise the bar higher in terms of energy efficiency and thermal comfort, as well as putting in place mechanisms that would show compliance of the final building, not just the design.
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