Environmental Sustainability Consultation Paper Submission to Housing NSW
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Environmental Sustainability
Consultation Paper
Submission to Housing NSW
March 2008
Contact: Andre Kaspura Richard Phillips
Policy Analyst, National & International Policy Director, Sydney Division
Engineers Australia Engineers Australia
11 National Circuit, Barton, ACT 2600 Level 3, 8 Thomas St,
Tel: 02 6270 6581 Chatswood 2067
akaspura@engineersaustralia.org.au 02 94105600Environmental Sustainability Consultation Paper: Housing NSW 1 INTRODUCTION Engineers Australia is the peak body for engineering practitioners in Australia, representing all disciplines and branches of engineering. Membership is now approximately 83,000 Australia wide and Engineers Australia is the largest and most diverse professional engineering association in Australia. All Engineers Australia members are bound by a common commitment to promote engineering and to facilitate its practice for the common good. Since 1989, Engineers Australia has had in place sustainable development principles to guide members in the conduct of their engineering practice. Sustainable development is an integral component of Engineers Australia’s code of ethics which are agreed by all members. Engineers Australia has also formally endorsed a Sustainability Charter and a comprehensive policy on Australia’s energy future and climate change. As long ago as 2001 an Engineers Australia Taskforce made a range of recommendations to governments, to engineers generally and to its organizational arm, to improve the energy efficiency of buildings and to demonstrate the commitment of the engineering profession to achieving improved building energy efficiency1. Although this Report focused on commercial buildings, the conclusions are just as applicable to residential housing. Over time important steps consistent with these recommendations have been taken up by State and Territory and Federal Governments and have significantly changed the status quo. Engineers Australia has repeatedly reaffirmed its commitment to energy efficiency in its policy development and in its representational efforts with decision makers because energy efficiency is an effective and inexpensive response to sustainable development. Furthermore, adopting energy efficiency approaches does not rely on future technologies. Instead there are numerous options available for immediate implementation, often at lower cost than conventional approaches. Engineers Australia welcomes this opportunity to comment on the Environmental Sustainability Consultation Paper released by Housing New South Wales. The general sentiments expressed in the paper are supported by Engineers Australia. Many of the current initiatives are 1 Engineers Australia, Sustainable Energy Innovation in the Commercial Building Sector, The Challenge of a New Energy Culture, Sustainable Energy Building and Construction Taskforce Report, November 2001, www.engineersaustralia.org.au Engineers Australia 1
Environmental Sustainability Consultation Paper: Housing NSW
innovative and important. However, in the context of recent
developments, including the NSW government’s emission reduction
target, Engineers Australia believes that a more ambitious approach is
needed.
2: HOUSING NSW’s VISION
In broad terms Engineers Australia supports the vision for the future
articulated in the Environmental Sustainability Consultation paper.
However, Engineers Australia notes that developments relating to
sustainable housing and impacting on the residents in them have
moved rapidly over the past year or so. Some of these developments
include:
• The incorporation of minimum energy efficiency provisions in the
Building Code of Australia (BCA)2.
• Recognition by States and Territories and by industry that as
well as minimum energy efficiency provisions in the BCA,
stakeholders should encourage best practice voluntary energy
efficiency initiatives3.
• All Australian governments have now articulated commitments
to reduce Australia’s greenhouse emissions by 2050 by 60%.
The focus of debate is now about how ambitious intermediate
targets should be with much of the weight of opinion in favour of
relatively ambitious targets for 2030.
• The rapid implementation of climate change mitigation policies
by the new Federal Government. Particularly important here are
the announcement that emissions trading will begin in 2010 and
the government’s commitment to a 20% renewable energy
target by 2020. Both emissions trading and the move to
renewable energy will lead to increasing electricity prices.
• The roll out of smart electricity meters to Australian consumers
scheduled to commence shortly. The impact of these meters will
be felt by users of electricity at peak times, for example by air-
conditioners on hot summer afternoons.
2
See the discussion on the web-site of the Department of Climate Change on building energy efficiency
www.environment.gov.au
3
Regulation Impact Statement, Proposal to Amend the Building Code of Australia to increase Energy
Efficiency Requirements for Houses, March 2006, www.abcb.gov.au
Engineers Australia 2Environmental Sustainability Consultation Paper: Housing NSW
While these, and other similar developments, do not alter the general
directions expressed in the vision statement, they do suggest the need
for a more specific approach which recognizes these and other events
and the magnitude of the challenges that lie ahead. The reality is that
Federal policy is forcing the pace on sustainability, particularly in
respect of climate related issues, because the costs of doing nothing
are considerably higher than the costs of change.
As Professor Garnaut indicates in his discussion paper on an emissions
trading scheme4, there will be direct price effects for consumers as
emissions trading increases energy prices, the impacts on low income
earners and disadvantaged groups are likely to be acute. There are
several ways to compensate for these effects. One way immediately
relevant to this Submission is to assist the residents who occupy
Housing NSW premises to reduce energy use through more energy
efficient houses. The technology to do this exists and can be
implemented now. A vision statement which recognizes that a house
with a 5 star NatHERS rating uses 30% less energy than a 4 star
rating and 40% less than a 3.5 star rating is more likely to resonate
with Housing NSW stake-holders5.
3: CURRENT INIATIVES
The list of current iniatives and achievements in the consultations
paper are impressive and worthy of widespread positive recognition.
Evaluation of them would demonstrate that many could readily be
extended to all housing under the administration of Housing NSW over
time. Engineers Australia recognizes that there are capital cost
implications, but believes that a well managed and staged approach
would succeed.
Engineers Australia believes that several of the iniatives dealing with
community understanding and acceptance of sustainable policies are
particularly valuable. However, realizing targets such as the NSW
government 60% emissions reduction target requires a dramatic
acceleration of such programs and their extension to all residents, not
just to public housing residents.
4
Garnaut Review, Emissions Trading Scheme Discussion Paper, March 2008, www.garnautreview.org.au
5
Regulation Impact Statement, op cit, pp5-6, www.abcb.gov.au
Engineers Australia 3Environmental Sustainability Consultation Paper: Housing NSW
4: THE CHALLENGE AHEAD
Opportunities for sustainability of Housing NSW policies should be
informed by the recent history of greenhouse emissions in the NSW
residential sector and the implications of the NSW government
emissions reduction target.
According to the Australian National greenhouse inventory6, direct and
indirect greenhouse emissions in the NSW residential sector grew from
25.6 MtCO2-e in 1990 to 32.2 MtCO2-e in 2005. This was an average
annual growth in emissions of 1.8% per annum. If unchecked this
growth would result in the NSW residential sector emitting 113.2
MtCO2-e by 2050, overall growth of 250% since 2005.
In order to meet the NSW government emission reduction target by
2050, emissions would need to be contained to no more than 40% of
emissions in the base year for the policy. The balance of discussion
accepts the end of the Kyoto period as the most suitable base year for
emissions reduction. Given present emissions growth and assuming
the reduction would be shared equitably across the NSW residential
sector, meeting the government’s target means that emissions from
the NSW residential sector should not exceed 13.6 MtCO2-e. In other
words, emissions of 99.6 MtCO2-e will need to be avoided. Housing
NSW is only responsible for a particular segment of the State’s
residential sector but its objectives should be informed by a need to
realize a similar proportional improvement in emissions from the
premises under its administration.
5: OPTIONS FOR CONSIDERATION
The consultation paper identifies four strategic priority areas with
several proposed opportunities identified under each of these
headings. Engineers Australia believes that the opportunities identified
may be strengthened in a number of ways.
Building design
• The energy efficiency expectation of new buildings should be
clearly stated in line with the COAG agreement that in addition
to mandatory minimum energy efficiency requirements for
residences through the Building Code of Australia, States and
Territories would encourage voluntary best practice by industry.
6
Australian Greenhouse Office, National Inventory by Economic Sector, 2007, www.greenhouse.gov.au
Engineers Australia 4Environmental Sustainability Consultation Paper: Housing NSW
The Building Code of Australia now provides for between 3.5 and
4 star energy efficiency. To demonstrate leadership to all
stakeholders Housing NSW should adopt a 5 star energy
efficiency target for all new premises and renovations.
• Similarly, the objective of water efficient premises could be
strengthened by specifying this objective in terms of the
parameters applicable to the WaterFix Program for both new and
existing premises.
• Replacing electric storage hot water systems in existing premises
is an important objective. It is, however, equally important in
new premises and while this is implied, it should be clearly
stated. While all hot water system options mentioned in the
consultation paper perform better than electric storage systems,
they are not emission free and there are relatively wide
variations in emissions between systems. Solar gas boosted
systems are almost emission free (0.2 tonnes annually in
Sydney) and the other systems produce 5-6 times higher
emissions7. Engineers Australia believes that it is incumbent on
Housing NSW to justify its choice of hot water system in the
context of the emissions reduction necessary to achieve the NSW
government’s emission reduction target.
• Voluntary mechanisms for energy efficiency have produced few
useful results. The reality is that substantial compliance with
energy efficiency ratings is integral to the Building Code of
Australia. Engineers Australia fails to understand why Housing
NSW cannot commit to mandatory building energy ratings
consistent with the trend throughout Australia.
Conservation of Natural Resources
• Engineers Australia supports the emphasis that Housing NSW
puts on recycling and reducing the amount of waste going to
landfill. Pressures from emissions trading will ensure that this
course of action pays off in the form of lower emissions and
costs in the future.
• Water sensitive urban design strategies are now an accepted
approach to sustainable building in most Australian cities.
Engineers Australia believes that it is insufficient for Housing
7
www.climatechange.gov.au/gwci/water.html
Engineers Australia 5Environmental Sustainability Consultation Paper: Housing NSW
NSW to simply promote these strategies for new developments
and retro-fits. Unless water sensitive urban design principles are
the basis for all future developments, the outcome will be more
case studies and minor advances in sustainable development.
Support Sustainable Communities
Here Engineers Australia believes that a clear distinction should be
drawn between two categories of activities that lead to greenhouse
emissions from Housing NSW programs:
• The operational activities of Housing NSW itself as an
organization, including internal administration, construction of
new premises, maintenance and renovation of existing premises
and the leadership role that Housing NSW fulfills in respect of its
business partners and tenants.
• The activities of tenants of Housing NSW premises.
Engineers Australia is supportive of all organizations taking stock of
the emissions arising from their own activities and taking steps to
reduce them. Indeed Engineers Australia is itself embarking on a
similar process. However, the policies and programs relating to these
activities should be clearly differentiated from the policies and
programs designed to encourage and facilitate tenants of Housing
NSW to do likewise.
The construction activities initiated by Housing NSW can provide
energy and water efficient facilities for tenants, but energy use in
houses goes beyond space heating and cooling and hot water systems.
About 40% of energy used in houses powers appliances, including
kitchen and entertainment appliances and home computers, lighting
and cooking. Additional reductions in greenhouse emissions can be
made by encouraging greater consciousness about energy efficiency
among Housing NSW tenants.
This can be in the form of energy efficient lighting installation
reinforced by information to tenants about the life cycle economic
benefits to them. Such reinforcement can be assisted by providing
ready access to replacement bulbs at attractive prices. It can also be
in the form of information about appliance energy ratings and access
to the computer based information systems available to select energy
efficient appliances. Poor appliance choice contributes to relative
disadvantage through the capital cost of appliances and through higher
running costs of less efficient ones.
Engineers Australia 6Environmental Sustainability Consultation Paper: Housing NSW Adapting to Climate Change An aggressive approach to raising the energy and water efficiency of Housing NSW premises is as much about climate change adaptation as it is about greenhouse emission reduction. An energy efficient building shell means improved comfort under most circumstances. Similarly, more widespread adoption of grey water recycling, rainwater tanks and native landscapes improve overall amenity. Engineers Australia believes that greater variability in climatic events will require a re-examination of general building standards to withstand more intense storms and higher temperatures. This issue still has a long way to play out and it is important that organizations with infrastructure responsibilities press for such a re-examination. 6: FINAL REMARKS Designing operational sustainable development plans is no trivial matter. The issues are complex and plans being developed now are influenced by rapidly changing federal policies on climate change mitigation. However, stability for planning is provided by well known and documented methodologies for achieving energy efficiency improvements in buildings and appliances. By aggressive application of well known and inexpensive approaches large gains in emission reduction are possible. In this way the more difficult reductions can be addressed by newer technologies as they become commercially available. Engineers Australia 7
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