[Coral-List] Australian Coral Reef Community - Climate Change Action - Mandatory Disclosure of Building Energy Efficiency

Eric Peterson e.peterson at uq.edu.au
Tue Aug 30 14:47:05 EDT 2011

This is primarily addressed to the Australian coral reef community.
Those overseas may be able to assist in our responses to the Council of Australian Governments (COAG)
Re: Residential Building Mandatory Disclosure (RBMD)

SUBMISSIONS close Monday 12 September 2011 Regarding COAG regulatory impact statement (RIS):
Mandatory disclosure of residential building energy, greenhouse and water performance
 http://www.mce.gov.au/ RIS by Allen Group (July 2011)

"Think outside the reef" and consider if building energy performance should be labled at the point of sale or lease?

Buildings account for 30-40% of global energy use.  Energy conservation applied to the built environment offers 29% global share of (low fruit) economic mitigation from projected business-as-usual GHG emissions 2020 “… using existing, mature technologies for energy efficiency that already exist widely and that have been successfully used.” - IPCC ar4 wgiii 2008
Market barriers, such as split incentives, and information failures impede investment in energy efficiency by households and business.  "A carbon price alone will not  realise all the opportunities to improve energy efficiency across the Australian economy"  - National Strategy on Energy Efficiency Memorandum of Understanding (COAG 2009)

"The politics behind this policy decision are complex. As such, this RIS is only the starting point of a process that is likely to take at least another 6 months before a resolution is achieved, and even then, the resolution may not be implemented in the straight-forward manner that we might reasonably expect. The main problem is that this policy has been driven from the Federal government, however according to the Australian Constitution, they have no power over regulating buildings, and thus must rely on the states to implement the outcomes of this RIS. Should any state not like the outcome of the RIS, it is within their powers to reject the outcome of the RIS and choose to implement it their own way."
- quote from Ross Maher,Association of Building Sustainability Assessors (ABSA)

Web seminars are available at
To register your participation in an online meeting, email details,
including your location, to buildings at climatechange.gov.au<mailto:buildings at climatechange.gov.au>.

For reef managers and researchers with little time to investiogate I suggest three
major problems with the RIS cost:benfit calculations that you could consíder putting in your submission:

First of all the RIS neglected benefits anyone other than householder
(what about the reefs, ecosystems, and human settlements).  The
Association of Building Sustainability Assessors (ABSA) asked me to
report back to Ross Maher if reef researchers could suggest what is the economic value of the GBR.
Short term loss of tourism, and long term what will be the cost to
society of having our Tsunami defense system disolve in carbonic acid?
Secondly the RIS assumed maximum asset life for householders only 20
years. Should not a well designed house have resale value in the future? Passive
thermal comfort should be more valuable in the future if there is a
price on carbon.

Thirdly thee RIS completely neglected the simple and sucessful NABERs Scheme
National Building Energy Ratings are the accepted method of mandatory
disclosure for commercial offices, and optional disclosure for hotels & retail.
The performance is entirely based on actual metering of electric power, gas and water.

Making Written submissions
Comments can be made on any aspect of the Consultation RIS. Of
particular importance is feedback from stakeholders and interested
parties on:
•       The extent of the ‘problem’ in residential building energy,
greenhouse and water performance. That is, to what extent are there
market failures, which present a barrier to improved energy,
greenhouse and water performance of residential buildings in
Australia? Has the problem been accurately represented in this RIS?
•       The adequacy of the options assessed in the Consultation RIS in
addressing the problem — are there any other feasible policy options
that should also be considered in the assessment?
•       The assessment of costs and benefits of options:
–       Does the assessment fully reflect all potential costs and benefits
of the options assessed?
–       Are there costs to industry that have not been accounted for?
–       Are the costs of the energy and water efficiency measures included
in the RIS reasonable?
–       Are the assumptions underlying the analysis valid/reasonable?
–       Are the take-up rates for the proportion of sellers and lessors that
invest in upgrades to their properties in each scenario reasonable?
–       The impact of the HIP upon the penetration of roof insulation in the
stock of Australian residential buildings.
•       Identified risks and uncertainties associated with each option.

Forward your submission to be recieved no later than COB Monday 12
September 2011:
•       via email (preferred) to: residentialdisclosure at climatechange.gov..au<mailto:residentialdisclosure at climatechange.gov.au>  OR
•       via mail to:    Residential Energy Efficiency Team, Buildings and
Government Energy Efficiency Branch
Department of Climate Change and Energy Efficiency , GPO Box 854.
Canberra ACT 2601
Any general enquiries regarding the Mandatory disclosure of
residential building energy, greenhouse and water performance
initiative should be directed to buildings at climatechange.gov.au<mailto:buildings at climatechange.gov.au>.

Eric Peterson
Adjunct Senior Lecturer, School of Biological Sciences, University of Queensland
Visiting Professor, Architectural Engineering, Victoria University
MOB: + 61 (0)4 39744682
E-mail: e.peterson at uq.edu.au<mailto:e.peterson at uq.edu.au>

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