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Consultation questions
From: J R Godfrey
Residential Efficiency Scorecard Assessor ( )
Background:
I am a retired chemical engineer. I worked for a major oil company for 37 years. After starting at a refinery in Adelaide I then worked in Melbourne, New Zealand, the USA and Europe.
Of relevance to this submission is that I was for a time the Energy Team Lead at a
Victorian refinery. I led work to better track site energy use and to identify and implement economic energy efficiency activities and projects. Site energy sources included both gaseous fuels and electricity.
I’m now a member of the Energy Innovation Co-Operative and also the Bass Coast Climate Action
Network.
Chapter 4. Objec ves and principles
1. What other objec ve could guide the expansion of NatHERS for exis ng homes?
Increase energy literacy for residents, home builders and associated trades.
2. Will the proposed design principles support informed decisions related to the expansion of
NatHERS?
Yes
3. Is anything missing or should any elements be removed from the design principles?
The design principles need to acknowledge up front that while ra ngs should be reasonably
accurate, for the ‘as built’ market absolute accuracy is not possible. For example, assessors
can’t see inside walls, and it’s o en tricky to assess ceiling insula on to see if the installa on
meets standards.
The principles of ‘repeatability’ and ‘reproducibility’ are both important here.
Repeatability is the likely varia on in score if the same assessor (or assessment firm) redoes the
assessment of the same home on a different day (without access to their original notes).
Reproducibility is the likely varia on in score if a different assessor does the assessment on the
same house without comparing notes with the other assessor.
(I know a lot about this from working with laboratories who test proper es like the octane of
gasoline or the specifica ons for avia on fuels. At one point I was Regional Product Quality
Advisor for the Asia Pacific region.)
To give examples of where and why this ma ers:
◦ A landlord chooses to rent out their newly built home, which has been designed,
per the Na onal Construc on Code (NCC), to NATHERS 7. They get a ra ng prior to
le ng it out and get a score of 6.4 – what happens then? Is 6.4 significantly
different from 7? Are ra ngs given to one decimal place? Does the NCC specify a
whole number or a decimal? Is the builder likely to be liable?
◦ A home owner applies for a green loan, where the condi ons include ge ng a
ra ng before the renova ons and a erwards. The expected improvement, to
qualify for the lower interest loan, is (say) 2 points. e.g. from NATHERS 3 to 5.
The ini al score is 3.2, the post renova on score is 4.7. Did the renova on meet
standard? Did you round up or down? Why?
◦ The minimal rental standard in an enlightened state or territory of Australia is that
rental proper es should be minimum 4 stars. An assessment is done and scores (of
course) 3.9. Can the home be rented out?
Analogies of all of the above examples have happened in the fuel tes ng world. I would
urge that you examine this during the pilot phase by deliberately having various home re-
tested by the same assessor (a couple of weeks or so apart) and also by different assessors
on different days (so they can’t influence each other). It’ll be important to use assessors
with varying levels of experience in this tes ng. Ideally, I suggest ge ng a supervisor /
manager, mentored by an assessor, to reflect what a “newbie” (but qualified) assessor
might come up with. They will learn a lot about the real challenges and complexi es of
assessing an as-built home.
I’m not an experienced assessor. From the few I’ve done the complexi es of the ‘as built’
world are quite daun ng. Having an ‘official’ sense that a score of 6.0 means (for legal
purposes) 5.7 to 6.3 (to guess a range) about 95% of the me is really important when you
scale this up and there are legal and financial consequences for a ra ng.
Chapter 5. Preferred delivery model
4. Are you suppor ve of the proposed delivery model?
Yes
5. Should elements of the alterna ve op ons or other successful programs (including Scorecard,
NatHERS for new homes and interna onal programs) be integrated into the preferred delivery
model to enhance design or for future enhancement?
Absolutely! NATHERS has to date largely worked in the theore cal world with almost no post
construc on inspec on to ensure that the house as built meets the design. YouTube and
Facebook both have numerous examples of “your insula on is in the ceiling, but it’s in the
original wrapping and stacked around the manway” type examples.
Victorian construc on codes:
◦ Require a building inspector to accept the builder’s personal signoff that wall insula on,
ceiling insula on etc were done to standard.
◦ Require a building inspector to accept the plumber’s signoff on water-proofing etc.
◦ Do not require an inspec on prior to the installa on of the internal plaster. So gaps in
thermal wrapping, air gaps around window or door frames etc are largely invisible in an
‘as built’ inspec on.
In a compe ve market, the cost pressures to cut corners versus NCC standards are very
real and do happen. Please make sure you talk with experienced Scorecard Assessors and
building surveyors about what they’ve seen.
6. How can we s mulate the market for assessor services and so ware?
A few things.
◦ Early warning, ac ve consulta on with relevant groups (major builders, valuers, real
estate agents etc) will be key. To misquote Roy & HG “Too much consulta on is barely
enough.”
◦ Ease the burden of liability insurance for raters / assessors. My current premium is over
$1000 / year, and that’s for advice given with no real financial consequence. In an
environment where there will be real and immediate financial consequences, I imagine
the risk of legal challenges etc could make insurance prohibi ve.
Chapter 6. Consumer experience
7. What elements of each cer ficate do you believe are most effec ve for communica ng with
consumers?
My experience with the Scorecard cer ficate is that clients take away the ‘headline’ number
and perhaps the top 2 or 3 improvement sugges ons. Energy literacy in Australia is low. Don’t
over-es mate how much informa on clients can absorb.
8. Do you support the concept of combining the presenta on of the thermal and Whole of Home
ra ng into one graphic on the cer ficate (no ng this does not combine the calcula on
method)?
I have found clients appreciate ge ng a Scorecard ‘score’ and also a winter and summer
ra ng. It also helps me understand what might be driving the model to produce the score it
has. From that I can suggest areas where the computer model is making assump ons that
don’t apply to the current client. Not everyone lives like the ‘average’.
9. What guidance informa on should be created to help consumers understand their Home
Energy Ra ng Cer ficate?
What’s proposed is ok from a ‘ra ngs only, no frills’ basis. Nothing will be having an assessor
sit down and spend me explaining it face to face. I do understand this will not be possible at
scale for all customers. So expect complaints, especially from people who don’t get the score
they expect. (See above re error band of ra ng scores.)
10. What support do you think can be provided to consumers at the me of assessment to drive
behaviour change? How might this be best communicated?
My experience is that it’s easy to overwhelm clients. So I make sure to leave them links to
helpful resources such as “My Efficient Electric Home” and other useful websites. (SolarQuotes
is excellent for solar PV / Home Ba eries / EV chargers.)
11. What informa on is important to include in guidance materials to support consumers to
understand upgrade advice?
See 10.
12. What communica on materials and media (e.g. websites, pamphlets, videos, webinars, paid
adver sing) would be most effec ve to communicate NatHERS for exis ng homes and home
energy ra ng disclosure requirements to consumers?
See 10.
13. What sources of informa on do you believe are the most trusted by consumers in the
residen al buildings space?
Face to face discussions with an assessor who has credibility. Their neighbours and community.
Their local trades – which isn’t always a good thing. Independent and government websites
such as ‘My Efficient Electric Home’, SolarQuotes, EnergyTips are very useful. Then there are
some long standing suppliers such as EcoMaster, Enviroflex etc who have excellent reputa ons
and very helpful websites.
14. What data do you want NatHERS to collect and how could it be used to benefit households?
I only recently became aware of the CSIRO Australian Housing Data. I think it’s a great idea and
I’m glad it’s there, but I don’t have the experience to comment further.
Chapter 7. Governance and administra on
15. Do you think the current NatHERS governance arrangements are suitable for exis ng homes?
Why / Why not?
I’m not familiar with them, so no comment.
Chapter 8. Assessor services
16. Are there any other areas where assessors will need guidance?
The ability to quickly get feedback on areas of uncertainty will be very important for assessors.
They need to feel supported. I’ve found the Scorecard system works well. I’m conscious though
that there are rela vely few Scorecard assessments being done now compared to what is
envisaged.
17. Are there considera ons for the workforce transi on that have not been captured?
See comments above about the likely increase in insurance liability premiums. It’d be worth
approaching insurance experts for their insights in this area, especially about how the
government(s) might lower the burden on assessors who comply with expecta ons.
18. Are there considera ons for assessor accredita on not reflected in the preferred approach?
I support the eased transi on for Scorecard Assessors. Personally I’ll be cau ous about moving
across as the energy advice piece is the most interes ng and engaging. The actual ‘ra ng’
piece is less useful. (I am re red and don’t need more income, so this may be unusual.)
19. Do you support the separa on of audit responsibili es from the assessor accredita on service
provider?
Yes, but it’s more ‘nice to have’ than mandatory.
20. Do you support a requirement for evidence to be collected so that assessments can be
verified?
Absolutely. The Scorecard system works well I think.
21. Do you support evidence being required to be uploaded as part of an assessment and stored in
a secure, central database?
Absolutely. The Scorecard system works well I think.
Chapter 9. Energy ra ng tools
22. Are there concerns we need to consider with the adop on of the cloud tool?
As long as you’ve work-shopped not having internet at a loca on then no.
23. Do you support the preferred approach of having front-end user interfaces delivered via third-
par es?
I can’t see why not.
24. Are there specific resources required to be er facilitate third-party tool or user interface
development?
Not experienced enough to comment on this.
General feedback
25. Do you have any other feedback on the consulta on paper?
Thank you for the seminars and this opportunity to comment.
