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2 September 2024
Department of Climate Change Energy Efficiency and Water
Australian Government
Canberra ACT 2601 Australia
Via email: admin@nathers.gov.au
Dear Home Ratings and Disclosure Branch,
Re: Expanding the Nationwide House Energy Rating Scheme
Green Building Council of Australia (GBCA) commends the Australian Government’s commitment to develop a method for assessing the energy performance of existing homes. GBCA supports the expansion the Nationwide House Energy Rating Scheme (NatHERS) to enable energy assessments and ratings for existing homes across the country.
In Every Building Counts,1 our policy platform first launched in 2019 in partnership with the Property
Council of Australia and refreshed in 2023, GBCA has advocated for a single national rating for home energy performance. The recommendation asks government to “empower owners, buyers and renters with a single national rating for home energy performance”.
A single, robust rating scheme consistently applied across the country would not only make it easier to compare the efficiency of homes, but would also create a market for better performing homes and provide added consumer protection for buyers and tenants.
We note this consultation is running in parallel to the consultation on the Home Energy Ratings Disclosure
Framework.2 The proposed Disclosure Framework will also rely on NatHERS ratings, making the proposed expansion of NatHERS a critical tool for measuring and improving the energy performance of homes in
Australia.
About GBCA
GBCA’s purpose is to lead the sustainable transformation of the built environment. We do this primarily through our core functions:
• We rate the sustainability of buildings, fitouts and communities through Australia's largest national,
voluntary, holistic rating system – Green Star.
• We educate industry, government practitioners and decision-makers, and promote green building
programs, technologies, design practices and operations.
• We advocate policies and programs that support our vision and purpose.
• We collaborate with our members and other stakeholders to achieve our mission and strategic
objectives.
1
https://everybuildingcounts.com.au/
2
https://consult.dcceew.gov.au/home-energy-ratings-disclosure-framework-version-2
Green Star is Australia’s most widely used sustainability rating system for the design, construction and performance of buildings – including social infrastructure – fitouts and communities. Green Star aims to transform the built environment by:
• reducing the impact of climate change
• enhancing our health and quality of life
• restoring and protecting our planet’s biodiversity and ecosystems
• driving resilient outcomes for buildings, fitouts, and communities
• contributing to market transformation and a sustainable economy.
Green Star Homes is a sustainability benchmark for assessing and rating individual houses based on standard designs and delivered by volume home builders. Green Star Homes seeks to create a market for homes that are healthy, resilient, efficient and powered by renewables. A certified Green Star Home is one that has been designed and constructed to be:
• Healthy – ventilated and comfortable to safeguard the health of those living in it
• Resilient – water efficient and climate change ready
• Positive – fully electric, draught sealed, efficient, and powered by renewables
Residential buildings are responsible for approximately a quarter of electricity use and more than 10% of
Australia’s total emissions. Improving the energy performance of homes is integral to Australia reaching net zero emissions by 2050.
A well planned and resourced implementation of NatHERS for existing homes has the potential to deliver on the Australian Government’s aim to help drive improvements to the energy performance of Australian homes, lower greenhouse gas emissions, improve the comfort and resilience of households, reduce energy costs and lower pressures on the energy system.
NatHERS for existing homes can provide baseline information for households to understand the energy performance of their homes empowering them to reduce running costs and to plan and implement upgrades to improve the energy performance. It will enable tenants and buyers to make more informed choices when selecting properties to rent or purchase. It can also create a standardised benchmark for the property management and banking and finance sectors to enable reporting and product development.
GBCA supports the new objectives and design principles to guide the expansion of NatHERS to existing homes and inform program decision making (Chapter 4 of the consultation paper) and recognise that the
Residential Efficiency Scorecard, ACT Energy Efficiency Rating and NatHERS for new homes have informed development. We note our alignment with other key industry stakeholders, such as the Australian
Sustainable Built Environment Council (ASBEC). The following feedback amplifies ASBEC’s submission to this consultation and offers further comment from GBCA intended to help ensure success of the initiative:
1. Strong governance mechanisms are the key to successful implementation of the scheme
expansion.
GBCA supports the proposed delivery model outlined in the consultation paper (Chapter 5) and
recognises that this is the pathway most likely to meet the need to deliver reliable, consistent and
comparable ratings at the lowest cost, while managing risk and minimising administrative burden
and complexity.
However, as the consultation paper rightly recognises in Chapter 5, this new delivery model is a
significant change from the current NatHERS for new homes model, which is conducted mainly via
a desktop process. Given that the current NatHERS governance structure outlined in Chapter 7 was
created to support the original process, we question whether this is an effective governance
structure for the complexities of a new on-site assessment process.
Further work is needed to develop governance processes that will more effectively govern a rating
scheme that will be rolled out in millions of homes across the nation. Consideration should be given
to how best to collect and consolidate the feedback provided by the hundreds of NatHERS
Stakeholder Consultative Group and Technical Advisory Group members. There is an opportunity
for DCCEEW to consider how to process the collection of scattered and fragmented opinions from
interests across the sector and turn this into meaningful information that will best support the
success of the NatHERS for existing homes scheme.
DCCEEW may also wish to consider an annual stakeholder survey written into governance
processes, providing the opportunity to get information on satisfaction with processes, necessary
updates that need to be implemented, tool correction needs, etc.
We support the proposal of having more centralised controls and streamlining of the software
accreditation process with a streamlined manner of driving the same outcomes. We also commend
the strengthening with binding arrangements for training and accreditation which is an
enhancement of the current NatHERS processes.
2. Consider providing more information on electrification opportunities in upgrade advice
International Energy Agency research stipulates that fossil gas is not part of the net zero by 2050
scenario for buildings.3 ASBEC’s Unlocking the Pathway confirms that electrification is the lowest
cost, fastest emissions reduction pathway for Australia’s built environment.4
Whilst we recognise that minimum standards in the current edition of the National Construction
Code (NCC2022) don’t yet support electrification, we strongly encourage NatHERS to consider some
form of disclosure in its end product delivery (refer to Chapter 6.2, Upgrade advice). For example,
NABERS provides a separate “Renewable Energy Indicator” in conjunction with its original energy
star rating, which allows the consumer to understand the presence of fossil gas in their building.
Fuel switching from gas to direct electricity is more energy efficient and will ultimately result in
lower consumer costs, better health and greater energy performance in homes. With ACT and VIC
governments rolling out policy around electrification, we suggest that extending disclosure this way
provides a tangible value add to these jurisdictions and will ultimately support a nationally
consistent approach to electrification.
3. Consider insourcing assessor services (training/accreditation/audit), or having one provider, to
ensure effective delivery
Noting that DCCEEW’s preferred option is to deliver assessor training, accreditation services and
audit via contracts between the NatHERS Administrator and third-party delivery partners, we
believe this might result in unintended future consequences. Many other rating systems have more
centralised approaches for accreditation, like leading international rating tools such as Green Star,
LEED, BREEAM, and NABERS.
As the owner and operator of Green Star, GBCA’s experience supports a centralised assessor
training and accreditation approach which better enables an efficient compliance framework and
3
https://www.iea.org/reports/net-zero-by-2050
4
https://www.asbec.asn.au/research-items/unlocking-the-pathway-why-electrification-is-the-key-to-net- zero-buildings/
consistent outcomes. This includes the ability to amend and/or updating training materials and
taking action to address substandard or unprofessional assessor activity.
We recognise that this might be a challenge in the current NatHERS environment so may not be
feasible initially; however, this should be considered the ideal model.
4. Objectives and principles
GBCA supports the new objectives and the proposed design principles for the expansion of
NatHERS to existing homes outlined in the consultation paper. The consultation paper states that
the new objectives will be considered alongside the previous new homes-focused objectives during
development of the next NatHERS Strategic Plan.
We encourage the government to consider inclusion of the following objective from the Strategic
Plan 2018 – 2022i in the new set of objectives:
The community and building industry are engaged and supported to obtain and use ratings and
information, through clear processes and communications.
While governments can apply the relevant policy levers to develop frameworks and programs to
achieve the desired outcomes, a sustainable program will require significant work to ensure market
acceptance and participation. This will not only ensure the program reaches its significant potential
for empowering homeowners, buyers and tenants and catalysing improvements to the existing
homes sector, it will allow it to generate sufficient income to become financially viable for all
participants. This is particularly important for practitioners looking to become NatHERS Assessors.
We commend the project team developing NatHERS for existing homes for building on the work
happening in states and territories and creating a centralised certification platform that will make it
easy for homeowners and occupiers across Australia to understand and compare the energy
performance of their homes.
We welcome the opportunity to provide further detail on any of the points or reports outlined above. For further information or to arrange a briefing, please contact Shay Singh, Senior Manager Policy and
Government Relations, via email at
Yours sincerely
Davina Rooney
Chief Executive
Green Building Council of Australia i
NathersStrategicPlan-2018-2022
