The Department of Climate Change, Energy, the Environment and Water (DCCEEW) has conducted a consultation on Version 2 of the Home Energy Ratings Disclosure Framework (the Framework).
The Framework expands on commitments made by Australian energy ministers to deliver a national framework for home energy efficiency disclosure as part of the Trajectory for Low Energy Buildings.
The Framework sets out a national approach for disclosing home energy efficiency ratings at point of sale or lease.
The Framework includes single dwellings — houses and townhouses — as well as apartments and apartment base buildings (for example, common areas and infrastructure).
The National Home Energy Rating Scheme (NatHERS) has been chosen to underpin the energy assessment of single dwellings and apartments.
The National Australian Built Environment Rating System (NABERS) has been chosen for the energy assessment of apartment base buildings.
DCCEEW is also conducting a separate consultation into the expansion of NatHERS to existing homes.
A robust national framework for home energy ratings disclosure, implemented in all states and territories, is an important step towards decarbonising Australia’s residential building sector. Climateworks’ Renovation Pathways program analysed the potential costs and benefits of improving the energy efficiency of existing residential buildings.
Mandatory disclosure of home energy efficiency ratings at point of sale or lease is a key recommendation and could help incentivise more energy efficient homes. Improving the energy efficiency of homes can have several benefits.
This includes reducing emissions, lowering energy bills for households, improving health and wellbeing, and reducing demand on the energy network from households.
Submission summary
Climateworks welcomes DCCEEW’s update to the Framework. Climateworks recommends the Framework be introduced by the Australian Government and supports making disclosure schemes mandatory in all states and territories. Climateworks also supports making ratings publicly available in de-identified formats through an opt-out consent process, noting that this information would be valuable for a range of stakeholders.
We recommend the following to strengthen the Framework:
2.1 Dwelling types
- Recommendation 1: Prioritise incorporating social and community housing into the next Framework iteration as ratings will enable social housing providers to identify priorities for improvements.
2.2 Disclosure triggers
- Recommendation 2: Increase clarity for consumers and industry by defining more precisely at what stage of preparation disclosure would be triggered under ‘when a property owner prepares to advertise their home for sale or lease’.
2.3 Energy ratings and assessments
- Recommendation 3: Include disclosure of NatHERS thermal ratings for single dwellings and apartments in sale and rental advertising materials, alongside Whole of Home ratings.
- Recommendation 4: Suggest that disclosure of ratings in sale and rental advertising materials displays whether homes have gas appliances and that advice to buyers encourages appliance electrification in line with state and territory efforts to phase out gas from residential buildings.
- Recommendation 5: Suggest assessors provide upgrade advice as part of the energy assessment process before renovation work if a home has not previously been rated or major renovations have been done since the last rating.
- Recommendation 6: If upgrade advice is provided before renovation work, suggest that state and territory schemes combine pre-renovation assessments for upgrade advice and post-renovation disclosure into a single streamlined process.
2.6 Communications
- Recommendation 7: Ensure ratings are communicated in a way that culturally and linguistically diverse (CALD) communities can easily understand them.
- Recommendation 8: Accompany the implementation of disclosure schemes with a public information campaign and link to one-stop-shops, where implemented.
- Recommendation 9: Suggest disclosure of the NatHERS certificate and ratings is made part of rental agreement documentation.
2.7 Validity periods
- Recommendation 10: Suggest that validity periods for single dwellings are initially set to five years and this timeframe is reviewed in future iterations of the Framework, with triggers for when a validity no longer applies or can be extended.
2.8 Phasing
- Recommendation 11: Suggest that disclosure schemes be implemented as a priority, and that disclosure includes existing homes at point of sale or lease from their commencement, so that all households benefit.
- Recommendation 12: Include a firm commitment within the Framework to include ratings for community, social and affordable housing stock within a set timeframe and be accompanied by funding for implementation.
Other questions
- Recommendation 13: Assist states and territories in designing and implementing disclosure schemes by setting out the advantages and disadvantages of mandatory and voluntary disclosure in the Framework.
- Recommendation 14: Continue collaboration between the Australian Government and states and territories to ensure implementation in all jurisdictions.